SECTION 3. EXTENSION OF SUNSET

DATE

Sections 5 and 6 of Rev. Proc. 2004–59 are amended as follows.

In Section 5.01, the following sentence is added after the existing text. “For section 1441 VCP submissions made after December 31, 2005, no extensions will be granted beyond June 30, 2006.”

In Section 6, the second sentence is amended by deleting “December 31, 2005” and inserting in its place, “March 31, 2006.” A third, fourth, and fifth sentence are added as follows: “A Section 1441 VCP submission may not be made for calendar year 2005 Forms 1042 and

1042-S. A Section 1441 VCP submission made after December 31, 2005, must include an executed Form 872, Consent to Extend the Time to Assess Tax, consenting to extend for one additional year the time to assess tax with respect to amounts reportable on Form 1042 for the 2002 year. If the withholding agent has filed a Form 945 for the 2002 year, it should further include an executed Form SS–10, Consent to Extend the Time to Assess Employment Taxes, to extend the assessment period for income tax withholding for an additional year.”