Part III. Administrative, Procedural, and Miscellaneous

As described in section 1.01 of Rev. Proc. 2003–64, a WP or WT agreement entered into during a calendar year may be made effective as of the first day of that calendar year. With the changes made by this revenue procedure, some foreign partnerships and trusts may wish to act as WPs or WTs beginning in 2003. Therefore, upon request, the IRS will execute WP and WT agreements with terms beginning on January 1, 2003, even if the application to enter into a WP or WT agreement was or is received after December 31, 2003, provided that the IRS receives the completed application on or before June 30, 2004.