SECTION 5. REQUEST FOR

COMMENTS

Section 4A.02 of the QI agreement and Section 10.02 of the WP and WT agreements allow the QI, WP, or WT to use simplified documentation, reporting, and withholding procedures if, among other things, the QI, WP, or WT is a general partner of the partnership or a trustee of the trust (the “related-party requirement”). The IRS and Treasury are reviewing the related-party requirement and solicit comments as to whether it presents difficulties for taxpayers considering participation in the QI, WP, or WT programs, and, if so, the reasons for such difficulties. Comments also are requested regarding the possibility of eliminating the requirement or modifying it to address any such difficulties, while ensuring consistency with the objectives of the underlying reporting and withholding regimes.

More generally, the IRS and Treasury remain committed to the QI, WP, and WT programs and are continuing to review them to ensure their optimal effectiveness. Therefore, comments are requested regarding additional ways the programs’ current rules and forms of agreement could be improved in a manner that is consistent with the objectives of the underlying reporting and withholding regimes.