Section 2. DEFINITIONS

For purposes of this Agreement, unless otherwise specified in this Agreement, the terms listed below are defined as follows. Any term not defined in this section has the same meaning that it has under the Code, including the income tax regulations under the Code, any applicable income tax treaty, or any applicable Model 1 IGA or Model 2 IGA with respect to WT’s FATCA requirements as a participating FFI, registered deemed-compliant FFI, or registered deemed-compliant Model 1 IGA FFI. Sec. 2.01. Account. “Account” has the meaning given to that term in § 1.1471– 1(b)(1) with respect to WT’s FATCA requirements. Sec. 2.02. Account Holder. “ Account Holder” has the meaning given to that term in § 1.1471–1(b)(2) with respect to WT’s FATCA requirements with respect to an account that it maintains within the meaning of § 1.1471–5(b)(5). Sec. 2.03. Agreement. “Agreement” means this Agreement between WT and the IRS, the Appendix to this Agreement, and WT’s application to become a withholding foreign trust. The Appendix to this Agreement and WT’s application are incorporated into this Agreement by reference. Sec. 2.04. Amount Subject to Chapter 3 Withholding. An “amount subject to chapter 3 withholding” is an amount described in § 1.1441–2(a), regardless of whether such amount is withheld upon. Sec. 2.05. Amount Subject to Chapter 4 Withholding. An “amount subject to chapter 4 withholding” is a withholdable payment (as defined in section 2.79 of this Agreement) for which withholding is required under chapter 4 or an amount for which withholding was otherwise applied under chapter 4. Sec. 2.06. Assuming Primary Withhold- ing Responsibility. “Assuming primary withholding responsibility” refers to when a WT assumes primary chapters 3 and 4 withholding responsibility with respect to amounts subject to chapter 3 or 4 withholding under the terms of the WT agreement. Generally, a WT assuming primary chapters 3 and 4 withholding responsibility relieves the person who makes a payment to the WT from the responsibility to

withhold. See sections 3.03 and 3.04 of this Agreement for when WT is required to withhold under this Agreement. Sec. 2.07. Beneficial Owner. A “beneficial owner” has the meaning given to that term in § 1.1441–1(c)(6). Sec. 2.08. Certified Deemed-Compliant FFI. “Certified deemed-compliant FFI” means an FFI described in § 1.1471– 5(f)(2), and includes a nonreporting Model 1 FFI and a nonreporting Model 2 FFI that is treated as a certified deemedcompliant FFI. Sec. 2.08. Chapter 3. Any reference to “chapter 3 of the Code” or “chapter 3” means sections 1441, 1442, 1443, 1461, 1463, and 1464. Sec. 2.09. Chapter 3 Reporting Pool. A chapter 3 reporting pool means a reporting pool described in section 6.02(D) of this Agreement. Sec. 2.10. Chapter 3 Status. The term “chapter 3 status” refers to the attributes of a payee (and a beneficiary or owner of WT for purposes of this Agreement) relevant for determining the rate of withholding with respect to a payment made to the payee for purposes of chapter 3. Sec. 2.11. Chapter 4. Any reference to “chapter 4 of the Code” or “chapter 4” means sections 1471, 1472, 1473, and 1474. Sec. 2.12. Chapter 4 Reporting Pool. A chapter 4 reporting pool means a reporting pool described in section 6.02(C) of this Agreement. Sec. 2.13. Chapter 4 Status. “Chapter 4 status” means the status of a person as a U.S. person, specified U.S. person, an individual that is a foreign person, a participating FFI, a deemed-compliant FFI, a restricted distributor, an exempt beneficial owner, a nonparticipating FFI, a territory financial institution, an excepted NFFE, or a passive NFFE. Sec. 2.14. Chapter 4 Withholding Rate Pool. A “chapter 4 withholding rate pool” means a pool of payees that are nonparticipating FFIs provided on a chapter 4 withholding statement (as described in § 1.1471–3(c)(3)(iii)(B)( 3 )) to which a withholdable payment is allocated. The term chapter 4 withholding rate pool also means a pool of payees provided on an FFI withholding statement (as described in § 1.1471–3(c)(3)(iii)(B)( 2 )) to which a withholdable payment is allocated to

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seded by any subsequent revenue procedure). Sec. 2.26. FFI Withholding Statement. An “FFI withholding statement” means a withholding statement provided by an FFI that meets the requirements of § 1.1471– 3(c)(3)(iii)(B)( 1 ) and ( 2 ). Sec. 2.27. Flow-Through Entity. A “flow-through entity” is a foreign partnership described in § 301.7701–2 or 3 (other than a withholding foreign partnership), a foreign trust that is described in section 651(a) (other than a withholding foreign trust), or a foreign trust if all or a portion of such trust is treated as owned by the grantor or other person under sections 671 through 679. With respect to an item of U.S. source FDAP income for which a treaty benefit is claimed, an entity is also a flow-through entity to the extent it is treated as fiscally transparent under section 894 and the regulations thereunder. Sec. 2.28. Foreign Financial Institution (FFI). “Foreign financial institution” or “FFI” has the meaning set forth in § 1.1471–5(d). Sec. 2.29. Foreign TIN. A “foreign TIN” is a taxpayer identification number issued by a foreign person’s country of residence. Sec. 2.30. Foreign Person. A “foreign person” is any person that is not a U.S. person and includes a nonresident alien individual, a foreign corporation, a foreign partnership, a foreign trust, and a foreign estate, as those terms are defined in section 7701 of the Code . For purposes of chapters 3 and 4, the term “foreign person” also means, with respect to a payment by a withholding agent, a foreign branch (including a foreign disregarded entity) of a U.S. person that provides a valid Form W–8IMY on which it represents that it is a QI. Sec. 2.31. Form W–8. “Form W–8” means IRS Form W–8BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals); IRS Form W–8BEN–E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities), IRS Form W–8ECI, Certificate of Foreign Person’s Claim That Income is Effectively Connected With the Conduct of a Trade or Business in the United States; IRS Form W–8EXP, Certificate of Foreign Government or Other Foreign Or

(A) A pool of payees consisting of each class of recalcitrant account holders described in § 1.1471–4(d)(6) (or with respect to an FFI that is a QI, a single pool of recalcitrant account holders that is not subdivided into classes of recalcitrant account holders described in § 1.1471– 4(d)(6)), including a separate pool of account holders to which the escrow procedures for dormant accounts apply; or (B) A pool of payees that are U.S. persons as described in § 1.1471–3(c)(3)(iii) (B)( 2 ). Sec. 2.15. Deemed-Compliant FFI. “Deemed-compliant FFI” means a certified deemed-compliant FFI, registered deemed-compliant FFI, or registered deemed-compliant Model 1 IGA FFI that is treated, pursuant to section 1471(b)(2) and § 1.1471–5(f), as meeting the requirements of section 1471(b). For the definition of certified deemed-compliant FFI, see section 2.08 of this Agreement. For the definition of registered deemedcompliant FFI, see section 2.61 of this Agreement. For the definition of registered deemed-compliant Model 1 IGA FFI, see section 2.62 of this Agreement. Sec. 2.16. Direct Beneficiary or Owner. A “direct beneficiary or owner” means a beneficiary or owner that is not an indirect beneficiary or owner (as defined in section 2.39 of this Agreement). Sec. 2.17. Distributive Share. “Distributive share” means an amount subject to chapter 3 withholding or an amount of a withholdable payment that is required to be distributed to the beneficiaries of a simple trust and an amount subject to chapter 3 withholding or an amount that is a withholdable payment includible in the income of the owners of a grantor trust. Sec. 2.18. Documentary Evidence. “Documentary evidence” means any documentation obtained under the appropriate know-your-customer rules (as defined in section 2.41 of this Agreement), or any documentary evidence described in § 1.1441–6 sufficient to establish entitlement to a reduced rate of withholding under an income tax treaty. Documentary evidence does not include a Form W–8 or Form W–9 (or an acceptable substitute Form W–8 or Form W–9). Sec. 2.19. Documentation. “Documentation” means any valid Form W–8, Form W–9 (or acceptable substitute Form W–8

or Form W–9), or documentary evidence, as defined in section 2.18 of this Agreement, including all statements or other information required to be associated with the form or documentary evidence. Sec. 2.20. Excepted NFFE. “Excepted NFFE” means a person described in § 1.1471–1(b)(41). Sec. 2.21. Exempt Beneficial Owner. “Exempt beneficial owner” means a person described in § 1.1471–1(b)(42) and includes any person that is treated as an exempt beneficial owner under an applicable Model 1 IGA or Model 2 IGA. Sec. 2.22. Exempt Recipient. An “exempt recipient” means a person described in § 1.6049–4(c)(1)(ii) (for interest, dividends, and royalties), a person described in § 1.6045–2(b)(2)(i) (for broker proceeds), and a person described in § 1.6041–3(p) (for rents, amounts paid on notional principal contracts, and other fixed or determinable income), for which no Form 1099 reporting is required. Exempt recipients are not exempt from reporting or withholding under chapter 3 or 4. Sec. 2.23. FATCA Requirements as a Participating FFI, Registered Deemed- Compliant FFI, or Registered Deemed- Compliant Model 1 IGA FFI. “FATCA requirements as a participating FFI, registered deemed-compliant FFI, or registered deemed-compliant Model 1 IGA FFI” means: (A) For a participating FFI, the requirements set forth in the FFI agreement; (B) For a registered deemed-compliant FFI (other than a reporting Model 1 FFI), the requirements under § 1.1471–5(f)(1) or the applicable Model 2 IGA; or (C) For a reporting Model 1 FFI and a registered deemed-compliant Model 1 IGA FFI, the requirements under applicable foreign law to implement the applicable Model 1 IGA. Sec. 2.24. Financial Institution (FI). “Financial institution” or “FI” has the meaning set forth in § 1.1471–5(e) and includes a financial institution as defined under an applicable Model 1 IGA or Model 2 IGA. Sec. 2.25. FFI Agreement. “FFI agreement” means an agreement of a participating FFI described in § 1.1471–4(a) and published in Revenue Procedure 2017–16, 2017–03 I.R.B.501 (as updated or super

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ganization for United States Tax Withholding and Reporting; and IRS Form W–8IMY, Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding and Reporting, as appropriate. It also includes any acceptable substitute Form W–8 as described under §§ 1.1441–1(e)(4)(vi) and 1.1471–3(c) (6)(v). Sec. 2.32. Form W–9. “Form W–9” means IRS Form W–9, Request for Taxpayer Identification Number and Certification , or any acceptable substitute Form W–9 as described under § 31.3406(h)– 3(c). Sec. 2.33. Form 1042. “Form 1042” means IRS Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons . Sec. 2.34. Form 1042–S. “Form 1042–S” means IRS Form 1042–S, Foreign Person’s U.S. Source Income Subject to Withholding. Sec. 2.35. Form 1099. “Form 1099” means IRS Form 1099–B, Proceeds From Broker and Barter Exchange Transactions; IRS Form 1099–DIV, Dividends and Distributions; IRS Form 1099–INT, Interest Income; IRS Form 1099–MISC, Miscellaneous Income; IRS Form 1099– OID, Original Issue Discount; and any other form in the IRS Form 1099 series appropriate to the type of payment required to be reported. Sec. 2.36. Form 3520–A, Owner State- ment, Beneficiary Statement, and State- ment Required Under Section 6048(b). “Form 3520–A” means IRS Form 3520–A, Annual Information Return of Foreign Trust with a U.S. Owner. “Owner Statement,” when referred to in connection with Form 3520–A, means a Foreign Grantor Trust Owner Statement. “Beneficiary Statement,” when referred to in connection with Form 3520–A, means a Foreign Grantor Trust Beneficiary Statement. The “statement required under section 6048(b)” means the Owner Statement and Beneficiary Statement. Sec. 2.37. Form 8966. “Form 8966” means IRS Form 8966, FATCA Report. Sec. 2.38. Global Intermediary Identifi- cation Number (GIIN). “Global intermediary identification number” or “GIIN” means the identification number that is assigned by the IRS to a participating FFI,

registered deemed-compliant FFI, direct reporting NFFE, or sponsoring entity. The term also includes the identification number assigned by the IRS to a reporting Model 1 FFI or registered deemedcompliant Model 1 IGA FFI for the purpose of identifying itself to withholding agents. Sec. 2.39. Indirect Beneficiary or Owner. An “indirect beneficiary or owner” is a person that owns an interest in WT through one or more passthrough beneficiaries or owners (as defined in section 2.54 of this Agreement). For example, a person that holds an account with a foreign intermediary or an interest in a flow-through entity which intermediary or flow-through entity, in turn, is a direct beneficiary or owner of WT is an indirect beneficiary or owner in WT. A person is an indirect beneficiary or owner of WT even if there are multiple tiers of intermediaries or flow-through entities between the person and WT. Sec. 2.40. Intermediary. An “intermediary” means a person that, for that payment, acts as a custodian, broker, nominee, or otherwise as an agent for another person, regardless of whether such other person is the beneficial owner of the amount paid, a flow-through entity, or another intermediary. Sec. 2.41. Know-Your-Customer Rules. “Know-your-customer rules” refers to the applicable laws, regulations, rules, and administrative practices and procedures governing the requirements of certain WTs that are FFIs to obtain documentation confirming the identity of WT’s direct beneficiaries or owners. A list of jurisdictions for which the IRS has received know-your-customer information and for which the know-yourcustomer rules and specified documentation are acceptable is available at: http://www. irs.gov/Businesses/International-Businesses/ List-of-Approved-KYC-Rules. Sec. 2.42. Marketable Securities. For purposes of this Agreement, the term “marketable securities” means those securities described in § 1.1441–6 for which a U.S. TIN or foreign TIN is not required to be provided by the beneficial owner to obtain treaty benefits. Sec. 2.43. Non-Consenting U.S. Ac- count. For purposes of a reporting Model 2 FFI, “non-consenting U.S. account” has

the meaning that such term has under the applicable Model 2 IGA. Sec. 2.44. Non-Exempt Recipient. A “non-exempt recipient” means a person that is not an exempt recipient under the definition in section 2.22 of this Agreement. Sec. 2.45. Non-Financial Foreign Entity (NFFE). A “non-financial foreign entity” or “NFFE” means a foreign entity that is not a financial institution (including an entity that is incorporated or organized under the laws of any U.S. territory and that is not a financial institution). The term also means a foreign entity treated as an NFFE pursuant to a Model 1 IGA or Model 2 IGA. Sec. 2.46. Nonparticipating FFI. A “nonparticipating FFI” means an FFI other than a participating FFI, a deemedcompliant FFI, or an exempt beneficial owner. Sec. 2.47. Nonqualified Intermediary. A “nonqualified intermediary” is any intermediary that is not a qualified intermediary. A nonqualified intermediary includes any intermediary that is a foreign person unless such person enters an agreement to be a qualified intermediary and acts in such capacity. A nonqualified intermediary also includes an intermediary that is a territory financial institution (as defined in § 1.1471–1(b)(130)) unless such institution agrees to be treated as a U.S. person. Sec. 2.48. Nonreporting Model 1 FFI. A “nonreporting Model 1 FFI” means a nonreporting financial institution described in Annex II of a Model 1 IGA. Sec. 2.49. Nonreporting Model 2 FFI. A “nonreporting Model 2 FFI” means a nonreporting financial institution described in Annex II of a Model 2 IGA. Sec. 2.50. Nonwithholding Foreign Partnership (NWP). A “nonwithholding foreign partnership” means a foreign partnership other than a withholding foreign partnership as defined in § 1.1441–5(c)(2). Sec. 2.51. Nonwithholding Foreign Trust (NWT). A “nonwithholding foreign trust” means a foreign trust (as defined in section 7701(a)(31)(B)) that is a foreign simple trust or a foreign grantor trust and that is not a withholding foreign trust (as defined in section 2.82 of this Agreement). Sec. 2.52. Overwithholding. The term “overwithholding” means any amount ac

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tually withheld (determined before application of the adjustment procedures described in section 7.01 of this Agreement) from an item of income or other payment that is in excess of: (A) The amount required to be withheld under chapter 4 with respect to such item of income or other payment, if applicable, and

(B) In the case of an amount subject to chapter 3 withholding, the actual tax liability of the beneficial owner of the income or payment to which the withheld amount is attributable, regardless of whether such overwithholding was in error or appeared correct at the time it occurred. For purposes of section 3406, the term “overwithholding” means the excess of the amount actually withheld under section 3406 over the amount required to be withheld. Sec. 2.53. Participating FFI. A “participating FFI” is defined in § 1.1471– 1(b)(91). Sec. 2.54. Passthrough Beneficiary or Owner. A “passthrough beneficiary or owner” is a direct or indirect beneficiary or owner of WT that is a nonqualified intermediary, a qualified intermediary that does not assume primary chapters 3 and 4 withholding responsibility with respect to payments of U.S. source FDAP income or primary Form 1099 reporting and backup withholding responsibility, or a flowthrough entity. As provided in section 2.27 of this Agreement, a withholding foreign partnership or withholding foreign trust is not a flow-through entity and thus is not a passthrough beneficiary or owner. Sec. 2.55. Payee. For purposes of chapter 3, a “payee” is defined in § 1.1441– 1(c)(12) and for purposes of chapter 4, a “payee” means a person described in § 1.1471–3(a). Sec. 2.56. Payment. A “payment” means an amount considered made to a person if that person realizes income whether or not such income results from an actual transfer of cash or other property. See § 1.1441–2(e). Sec. 2.57. Payor. A “payor” is defined in § 31.3406(a)–2 and § 1.6049–4(a)(2) and generally means any person required to make an information return under chapter 61. Sec. 2.58. Pooled Reporting (PR) Elec- tion. A “pooled reporting election” or “PR

election” is an election to pool report chapter 3 reporting pools on Form 1042–S for chapter 3 purposes as described in section 6.02(D) of this Agreement. Sec. 2.59. Qualified Intermediary (QI). A “qualified intermediary” or “QI” is a person (or branch) described in § 1.1441– 1(e)(5)(ii) that has in effect an agreement with the IRS to be treated as a QI and acts as a QI. See Rev. Proc. 2017–15, 2017–03 I.R.B. 437 (as updated or superseded by any subsequent revenue procedure), for the QI Agreement. Sec. 2.60. Recalcitrant Account Holder. A “recalcitrant account holder” means a person described in § 1.1471–5(g). Sec. 2.61. Registered Deemed-Compliant FFI. “Registered deemed-compliant FFI” means an FFI described in § 1.1471– 5(f)(1) and includes a reporting Model 1 FFI and a nonreporting Model 2 FFI that is treated as a registered deemedcompliant FFI. Sec. 2.62. Registered Deemed-Compliant Model 1 IGA FFI. “Registered deemedcompliant Model 1 IGA FFI” means an FFI treated as a deemed-compliant FFI under an applicable Model 1 IGA that is subject to similar due diligence and reporting requirements with respect to U.S. accounts as those applicable to a registered deemed-compliant FFI under § 1.1471–5(f)(1), including the requirement to register with the IRS. Sec. 2.63. Reportable Amount. A “reportable amount” means U.S. source FDAP income that is an amount subject to chapter 3 withholding (as defined in section 2.04 of this Agreement), U.S. source deposit interest (as defined in section 871(i)(2)(A)), and U.S. source interest or original issue discount paid on the redemption of short-term obligations (as defined in section 871(g)(1)(B)(i)). The term does not include payments on deposits with banks and other financial institutions that remain on deposit for two weeks or less. It also does not include amounts of original issue discount arising from a sale and repurchase transaction completed within a period of two weeks or less, or amounts described in § 1.6049–5(b)(7), (10), or (11) (relating to certain foreign targeted registered obligations and certain obligations issued in bearer form). Sec. 2.64. Reporting Model 1 FFI. A “reporting Model 1 FFI” means an FFI

with respect to which a foreign government or agency thereof agrees to obtain and exchange information pursuant to a Model 1 IGA, other than an FFI that is treated as a nonreporting Model 1 FFI (including a registered deemed-compliant Model 1 IGA FFI) or nonparticipating FFI under an applicable Model 1 IGA. Sec. 2.65. Reporting Pool. A “reporting pool” is defined in section 6.02(A) of this Agreement. Sec. 2.66. Responsible Officer. A “responsible officer” of a WT means the trustee of WT or an agent of the trustee of WT with sufficient authority to fulfill the duties of a responsible officer as described in section 8 of this Agreement, including the requirements to periodically certify and to respond to requests by the IRS for additional information to review WT’s compliance with this Agreement. Sec. 2.67. Retirement Fund. A “retirement fund” means a retirement fund or other fund that is an exempt beneficial owner described in § 1.1471–6(f) or a similar fund that qualifies as an exempt beneficial owner under an applicable Model 1 IGA or Model 2 IGA. Sec. 2.68. Sponsored Direct Reporting NFFE. The term “sponsored direct reporting NFFE” has the meaning set forth in § 1.1472–1(c)(5). Sec. 2.69. Sponsored FFI. The term “sponsored FFI” means any entity described in § 1.1471–5(f)(1)(i)(F) (sponsored investment entities and sponsored controlled foreign corporations) or § 1.1471–5(f)(2)(iii) (sponsored, closely held investment vehicles). Sec. 2.70. Sponsoring Entity. “Sponsoring entity” means (i) an entity that registers with the IRS and agrees to perform the due diligence, withholding, and reporting obligations of one or more sponsored FFIs pursuant to § 1.1471–5(f) (1)(i)(F) or (f)(2)(iii); or (ii) an entity that registers with the IRS and agrees to perform the due diligence and reporting obligations of one or more direct reporting NFFEs pursuant to § 1.1472–1(c)(5). Sec. 2.71. Trust, Beneficiary, and Owner. The term “trust” is defined in § 301. 7701–4. The term “beneficiary” is defined in section 643(c) of the Code and the regulations thereunder. An “owner” is a grantor under § 1.671–2(e) or a person

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treated as an owner under sections 671 to 679 and the regulations thereunder. Sec. 2.72. Underwithholding. “Underwithholding” means the excess of the amount required to be withheld under chapter 3 or 4 over the amount actually withheld. Sec. 2.73. Undocumented Beneficiary or Owner. An “undocumented beneficiary or owner” is a beneficiary or owner for whom WT does not have valid documentation. Sec. 2.74. U.S. Account. A “U.S. account” is any financial account maintained by a participating FFI or registered deemed-compliant FFI that is held by one or more specified U.S. persons or U.S. owned foreign entities that such FFI reports or elects to report under the FFI agreement or § 1.1471–5(f), as applicable. A U.S. account includes, in the case of a reporting Model 1 FFI or registered deemed-compliant Model 1 IGA FFI, a U.S. reportable account as defined in section 2.76 of this Agreement. Sec. 2.75. U.S. Person. A “United States person” (or “U.S. person”) is a person described in section 7701(a)(30), the U.S. government (including an agency or instrumentality thereof), a State of the United States (including an agency or instrumentality thereof), or the District of Columbia (including an agency or instrumentality thereof). An individual will not be treated as a U.S. person for purposes of this Agreement for a taxable year or any portion of a taxable year that the individual is a dual resident taxpayer (within the meaning of § 301.7701(b)–7(a)(1)) who is treated as a nonresident alien pursuant to § 301.7701(b)–7 for purposes of computing the individual’s U.S. tax liability. A U.S. person does not include an alien individual who has made an election under section 6013(g) or (h) to be treated as a resident of the United States. For chapter 4 purposes, the term “U.S. person” or “United States person” also means a foreign insurance company that has made an election under section 953(d), provided that either the foreign insurance company is not a specified insurance company (as described in § 1.1471–5(e)(1)(iv)), or the foreign insurance company is a specified insurance company and is licensed to do business in any State of the United States. Sec. 2.76. U.S. Reportable Account. A

“U.S. reportable account” means a financial account maintained by a reporting Model 1 FFI or registered deemedcompliant Model 1 IGA FFI that such FFI reports or elects to report under the applicable domestic law for compliance with and implementation of FATCA. Sec. 2.77. U.S. Source FDAP. “U.S. source FDAP” means amounts from sources within the United States that constitute fixed or determinable annual or periodical income, as defined in § 1.1441– 2(b)(1). Sec. 2.78. U.S. TIN. A “U.S. TIN” means a U.S. taxpayer identification number assigned under section 6109. Sec. 2.79. Withholdable Payment. A “withholdable payment” means an amount described in § 1.1473–1(a). Sec. 2.80. Withholding Agent. A “withholding agent” has the same meaning as set forth in § 1.1441–7(a) for purposes of chapter 3 and as set forth in § 1.1473–1(d) for purposes of chapter 4 and includes a payor (as defined in section 2.57 of this Agreement). Sec. 2.81. Withholding Foreign Part- nership (WP). A “withholding foreign partnership” or “WP” means a partnership, described in § 1.1441–5(c)(2), that has in effect a withholding agreement with the IRS to be treated as a withholding foreign partnership. Sec. 2.82. Withholding Foreign Trust (WT). A “withholding foreign trust” or “WT” means a trust, described in § 1.1441–5(e)(5)(v), that has in effect a withholding agreement with the IRS to be treated as a withholding foreign trust. Sec. 2.83. WT-EIN. A “WT-EIN” means the employer identification number assigned by the IRS to a WT. WT’s WTEIN is only to be used when WT is acting as a WT. For example, WT must give a withholding agent its EIN (other than its WT-EIN), if any, if it is not acting as a WT (i.e., acting as a nonwithholding foreign trust) and a taxpayer identification number is required.