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Introduction

SECTION 1. PURPOSE

Internal Revenue Bulletin 2005-51 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure modifies the final withholding foreign partnership (“WP”) and withholding foreign trust (“WT”) agreements, contained in Rev. Proc. 2003–64, 2003–2 C.B. 306, by expanding the availability of certain documentation, reporting, and withholding

procedures. This revenue procedure also makes a conforming change to the portion of the Qualified Intermediary (“QI”) withholding agreement (the “QI agreement”) contained in Rev. Proc. 2003–64.

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▸Contents — Internal Revenue Bulletin 2005-51

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