Bulletin No. 2017–6 February 6, 2017

procedure. The WP and WT agreements are updated consistent with recently published guidance, including the qualified intermediary withholding agreement, which was published in Revenue Procedure 2017–15. The revenue procedure also provides information on submitting an application or request for renewal of a WP or WT agreement.

T.D. 9810, page 775. In general, S corporations, regulated investment companies (“RICs”), and real estate investment trusts (“REITs”) are not taxed at the corporate level (in the case of S corporations) or rarely incur corporate-level tax (in the case of RICs and REITs). An exception to this general rule occurs when an S corporation, a RIC, or a REIT disposes of certain property previously held by a C corporation within a specified period of time, known as the “recognition period.” The length of the recognition period for S corporations is provided by statute, while the length of the recognition period for RICs and REITs is provided by regulations. These final regulations will conform the length of the recognition period for RICs and REITs to the length of the recognition period for S corporations.