Section 12. EFFECTIVE DATE OF

AGREEMENT The text of the WP agreement is set forth below. The IRS will not provide signed copies of the WP agreement. A reporting Model 2 FFI should interpret this Agreement by substituting the term “reporting Model 2 FFI” for “participating FFI” throughout this Agreement, except in cases where this Agreement explicitly refers to a reporting Model 2 FFI. A reporting Model 1 FFI and a nonreporting Model 2 FFI treated as a registered deemedcompliant FFI should apply this Agreement by substituting the term “reporting Model 1 FFI” or “nonreporting Model 2 FFI,” as applicable, for “registered deemedcompliant FFI” throughout this Agreement, except in cases where this Agreement explicitly refers to a reporting Model 1 FFI or nonreporting Model 2 FFI treated as a registered deemed-compliant FFI.

WHEREAS, WP has submitted an application in accordance with this revenue procedure to be a withholding foreign

February 6, 2017 796 Bulletin No. 2017–6

partnership for purposes of § 1.1441– 5(c)(2); WHEREAS, WP and the IRS desire to enter into an agreement to establish WP’s rights and obligations regarding documentation, withholding, information reporting, tax return filing, deposits, and refund procedures under sections 1441, 1442, 1443, 1461, 1471, 1472, 1474, 6031, 6302, 6402, and 6414 with respect to certain types of payments;

WHEREAS, WP represents that there are no legal restrictions that prohibit it from complying with the requirements of this Agreement;

WHEREAS, if WP is a foreign financial institution (other than a retirement fund), WP represents that it has agreed to comply with the requirements of the FFI agreement, in the case of a participating FFI (including a reporting Model 2 FFI); § 1.1471–5(f)(1) or the applicable Model 2 IGA, in the case of a registered deemedcompliant FFI (other than a reporting Model 1 FFI); or an applicable Model 1 IGA, in the case of a reporting Model 1 FFI or a registered deemed-compliant Model 1 IGA FFI beginning on the effective date of this Agreement;

NOW, THEREFORE, in consideration of the following terms, representations, and conditions, the parties agree as follows: