PART IV. PERIODIC — Internal Revenue Bulletin 2017-6

FACTUAL INFORMATION

This Part IV must be completed by all WPs that have not received a waiver. If a Compliance Entity is completing this form for WPs in its consolidated compliance program, complete Part IV separately for each WP. For purposes of this Part IV, “partner” means, unless otherwise specified, any direct or indirect partner for which WP acts as a withholding foreign partnership. For Sections B through G of this Part IV,

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while the curing of inadequate documen- tation is permissible, unless otherwise in- dicated, the information reported shall be based on the review and not results ob- tained after curing.

A. General Information

Did WP use an external reviewer to conduct any portion of its periodic review? Y/N

a. If yes, provide the name(s) of

reviewer(s) and the name and address of the firm at which the reviewer is employed. 2. Did WP use an internal reviewer to conduct any portion of its periodic review? Y/N

a. If yes, provide a brief description

of the internal reviewer, such as their department and other roles and responsibilities with respect to the WP’s WP activities. 3. Calendar year reviewed for periodic review. Caution: On the due date for reporting the factual information relating to the peri- odic review (provided in section 8.04 of the WP Agreement), there must be 15 or more months available on the statutory period for assessment for taxes reportable on Form 1042 of the calendar year for which the review was conducted or the WP must submit, upon request by the IRS, a Form 872, “Consent to Extend the Time to Assess Tax,” that will satisfy the 15- month requirement. The Form 872 must be submitted to the IRS at the address provided in section 11.06 of the WP Agreement.

B. General Information on Partners and Review of Partners

Total partners reviewed for periodic review. Note: WP must review all partners that received a distribution, or included in their distributive share, of a reportable amount that is attributable to an amount paid to WP in the year under review.

C. Documentation

Total partners reviewed that are direct partners.
Total partners reviewed that are indirect partners.
Total partners reviewed with valid documentation.
Total partners reviewed with invalid documentation or no documentation.
Total partners reviewed with invalid documentation or no documentation for which valid documentation or additional valid documentation was obtained after the review.
Total direct partners reviewed for which WP had no documentation at any time that withholding or reporting was required under section 3.02 of the WP Agreement.
Total direct partners in question 6 for which valid documentation (that relates to the time withholding or reporting was required) was obtained by WP for each such undocumented direct partner before March 15 of the year following the year in which the WP Agreement was automatically terminated under section 10.03(A) of the WP Agreement.
Total partners reviewed for which treaty benefits were claimed.
Total partners reviewed for which treaty benefits were claimed where WP did not obtain sufficient documentation to establish the payee’s entitlement to treaty benefits (including, where applicable, the treaty statement and limitation on benefits information required by section 4.03(B) of the WP Agreement).
Total partners reviewed that are U.S. accounts (or U.S. reportable accounts under an applicable Model 1 IGA) for chapter 4 purposes.
Total partners reviewed that are U.S. accounts for chapter 4 purposes (or U.S. reportable accounts under an applicable Model 1 IGA) for which WP has obtained valid documentation.
If WP is an NFFE, total partners reviewed that are passive NFFEs with substantial U.S. owners.

D. Withholding

The aggregate amount reported as withheld under chapter 3 by WP on Forms 1042–S.
Number of partners for which amounts were withheld under chapter 3 (excluding partners reported in question 10(a) or 11(a) below).
The aggregate amount reported as withheld under chapter 4 by WP on Forms 1042–S.
Number of partners for which amounts were withheld under chapter 4 (excluding partners reported in question 10(a) or 11(a) below).
The aggregate amount reported as withheld by WP on Form 1042 under chapter 3 or 4.
Additional withholding required under chapter 4 based on the results of the periodic review (excluding withholding reported in question 10(d) or 11(d) below).
Additional withholding required under chapter 3 based on the results of the periodic review (excluding withholding reported in question 10(d) or 11(d) below).
The aggregate amount of deposits made by WP in accordance with section 3.05 of the WP Agreement.
The aggregate amount withheld by WP but not timely deposited.
Number of partnerships or trusts to which the joint account option of section 9.01 of the WP Agreement was applied (if applicable).

a. Total partners, beneficiaries, or

owners of a partnership or trust to which the joint account option applied for which appropriate documentation was obtained and the appropriate rate of withholding was applied. b. Total partners, beneficiaries,

or owners of a partnership or trust to which the joint account option applied for which appropriate documentation was obtained and the appropriate rate of withholding was not applied.

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c. Total partners, beneficiaries, or

owners of a partnership or trust to which the joint account option applied for which appropriate documentation was not obtained and the appropriate rate of withholding was not applied. d. Aggregate amount of under withholding resulting from the appropriate rate of withholding not being applied with respect to a partner, beneficiary, or owner of a partnership or trust to which the joint account option applied. 11. Number of partnerships or trusts to which the agency option of section 9.02 of the WP Agreement was applied (if WP includes the partnership or trust in WP’s periodic review).

a. Total partners, beneficiaries, or

owners of a partnership or trust to which the agency option applied for which appropriate documentation was obtained and the appropriate rate of withholding was applied. b. Total partners, beneficiaries,

or owners of a partnership or trust to which the agency option applied for which appropriate documentation was obtained and the appropriate rate of withholding was not applied. c. Total partners, beneficiaries, or

owners of a partnership or trust to which the agency option applied for which appropriate documentation was not obtained and the appropriate rate of withholding was not applied. d. Aggregate amount of under withholding resulting from the appropriate rate of withholding not being applied with respect to a partner, beneficiary, or owner of a partnership or trust to which the agency option applied.

E. Reconciliation of Amounts Reported on Forms 1042–S

The aggregate amount reported paid to WP during the year under review on all Forms 1042–S issued to WP (acting as a withholding foreign partnership).
The aggregate amount reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, partners that are included in WP’s chapter 4 reporting pools (other than the U.S. payee pool) (including a chapter 4 reporting pool of a partnership or trust to which WP applies the agency option) to the extent such amount is attributable to an amount paid to WP in the year under review.
The aggregate amount reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, WP’s chapter 4 reporting pool- U.S. payee pool to the extent such amount is attributable to an amount paid to WP in the year under review.
If WP made a pooled reporting election under section 6.02(D) of the WP Agreement, the aggregate amount reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, WP’s chapter 3 reporting pools (including chapter 3 reporting pools of a partnership or trust to which WP applies the joint account or agency option) to the extent such amount is attributable to an amount paid to WP in the year under review.
If WP did not make a pooled reporting election, the aggregate amount of reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, each direct partner (other than a passthrough partner) (not included in question 2 or 3 above) to the extent such amount is attributable to an amount paid to WP in the year under review (excluding an amount reported in question 6 below).
The aggregate amount reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, other WPs, WTs, and

QIs as a class to the extent such amount is attributable to an amount paid to WP in the year under review. 7. The aggregate amount reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, participating FFIs, registered deemed-compliant FFIs, and registered deemed-compliant Model 1 IGA FFIs that are passthrough partners to which WP applies section 9.03 of the WP Agreement as a class with respect to their chapter 4 reporting pools to the extent such amount is attributable to an amount paid to WP in the year under review (excluding amounts included in question 6 above). 8. The aggregate amount reported by WP on Forms 1042–S as distributed to, or included in the distributive share of, indirect partners (not included in any of the questions above) to which WP applies section 9.03 of the WP Agreement to the extent such amount is attributable to an amount paid to WP in the year under review. 9. The aggregate amount subject to chapter 3 withholding that WP distributed to, or included in the distributive share of, U.S. partners not included in a chapter 4 withholding rate pool to the extent such amount is attributable to an amount paid to WP in the year under review. 10. The aggregate amount distributed to, or included in the distributive share of, direct partners of WP (including partners, beneficiaries, or owners of a partnership or trust to which WP applies the joint account or agency option) that requested individual Form(s) 1042–S and direct partners that were issued Forms 1042–S under section 6.02(B)(8) of the WP Agreement (excluding an amount reported in question 4 above). 11. Total of questions 2 through 10. 12. The amount of any unreconciled variances (if question 1 minus question 11 is other than 0). 13. The aggregate amount reported by WP on Form 1042 as distributed to, or included in the distributive

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share of, partners of WP to the extent such amount is attributable to an amount paid to WP in the year under review. 14. The amount of any unreconciled variances of amounts reported by WP on Forms 1042 and 1042–S (question 13 minus the total of questions 2 through 8). 15. The aggregate amount of any collective claims for refund or credit made by WP.

F. Reporting of Reportable Amounts Other Than Amounts Subject to Chapter 3 Withholding

The aggregate amount of reportable amounts other than amounts subject to chapter 3 withholding received by WP.
The aggregate amount of reportable amounts other than amounts subject to chapter 3 withholding distributed to, or included in the distributive share of, a direct partner that is a U.S. person.
Number of direct partners that are U.S. persons that are not reported on Schedules K–1 to Form 1065 or under WP’s FATCA requirements (if none enter 0).

G. Reporting on Form 1065 and Schedules K–1

WPs that are exempt from filing Schedules K–1 under section 6.03(B) (Modified Fil- ing Obligations) or 6.03(C) (Foreign Re- verse Hybrid Entities) of the WP Agree- ment should not complete this section G.

The total number of Schedules K–1 issued by WP to partners that are U.S. persons for the year under review.
The total number of Schedules K–1 issued by WP to partners that are foreign persons for the year under review.
The aggregate amount of special allocations to partners that are foreign persons for the year under review (if none enter 0).