Section 11. MISCELLANEOUS

PROVISIONS

Sec. 11.01. WT’s application to become a WT, the Appendix to this Agreement, and, if WT is an FFI, its FATCA requirements as a participating FFI, registered deemedcompliant FFI, or registered deemedcompliant Model 1 IGA FFI (or, if WT is a sponsoring entity, the due diligence, withholding, reporting, and compliance requirements of a sponsoring entity) are hereby incorporated into and made an integral part of this Agreement. This Agreement, WT’s application, and the Appendix to this Agreement constitute the complete agreement between the parties. Sec. 11.02. This Agreement may be amended by the IRS if the IRS determines that such amendment is needed for the sound administration of the internal revenue laws or internal revenue regulations. This Agreement will only be modified through published guidance issued by the IRS and U.S. Treasury Department. Any such modification imposing additional requirements will in no event become effective until the later of 90 days after the IRS provides notice of such modification or the beginning of the next calendar year following the publication of such guidance. Sec. 11.03. Any waiver of a provision of this Agreement by the IRS is a waiver solely of that provision. The waiver does not obligate the IRS to waive other provisions of this Agreement or the same provision at a later date. Sec. 11.04. This Agreement shall be governed by the laws of the United States. Any legal action brought under this Agreement shall be brought only in a U.S. court with jurisdiction to hear and resolve matters under the internal revenue laws of the United States. For this purpose, WT agrees to submit to the jurisdiction of such U.S. court. Sec. 11.05. WT’s rights and responsibilities under this Agreement cannot be assigned to another person. Sec. 11.06. Except as otherwise provided in the QI/WP/WT Application and Account Management System, notices provided under this Agreement shall be mailed registered, first class airmail. All notices sent to the IRS must include the WT’s name, WT-EIN, GIIN (if applica

Bulletin No. 2017–6 855 February 6, 2017

(B) Calendar Year 2017. If a WT is approved for WT status during calendar year 2017, the rules described in section 12.01(A) of this Agreement apply, except that the WT agreement effective from January 1, 2017, to the date of issuance of this revenue procedure will be the WT agreement in Revenue Procedure 2014– 47, and the WT agreement provided in this revenue procedure will be effective beginning on the date of issuance of this revenue procedure. Sec. 12.02. Renewal of WT Agreement. A WT that applies to renew its WT agreement provided in Revenue Procedure 2014–47 on or before March 31, 2017, will have a WT agreement with an effective date of the date of issuance of this revenue procedure.

ble), and the name of its responsible officer. Such notices shall be directed as follows: To the IRS: Internal Revenue Service Foreign Payments Practice Foreign Intermediaries Program 290 Broadway, 12 ^th Floor New York, NY 10007-1867 To WT: The WT’s responsible officer. Such notices shall be sent to the address indicated in the WT’s registration or application (as may be amended). Sec. 11.07. WT, acting in its capacity as a withholding foreign trust or in any other capacity, does not act as an agent of the IRS, nor does it have the authority to hold itself out as an agent of the IRS.

APPENDIX TO WT AGREEMENT