SECTION 2. BACKGROUND

Rev. Proc. 2003–64 contains the WP and WT agreements described in Treasury Regulation § 1.1441–5(c)(2)(ii) and (e)(5)(v) and sets forth the application procedures for entering into such agreements. Rev. Proc. 2003–64 also amended the QI agreement, contained in Rev. Proc. 2000–12, 2000–1 C.B. 387, to add new

December 19, 2005 1176 2005–51 I.R.B.

or WT may apply the Agency Provision only if, among other things, the QI (or an affiliate), WP or WT is a general partner of the partnership or a trustee of the trust (the “relatedness requirement”). Upon consideration of comments received, the IRS and the Treasury Department have concluded that the relatedness requirement is unnecessary and that its elimination will facilitate compliance consistent with the objectives of the underlying reporting and withholding regimes.