SECTION 9. ADJUSTMENTS — Internal Revenue Bulletin 2022-20

FOR OVER- AND UNDER- WITHHOLDING; REFUNDS

May 16, 2022 1074 Bulletin No. 2022–20

10.03. Certification of Internal Con- trols by Responsible Officer.

(B) Material Failures. (1) Material Failures Defined.

**(iv) * * *** (i) Withhold an amount that QI was required to withhold on a payment of an amount realized from the sale of a PTP interest or on a PTP distribution as required under section 3 of this Agreement or provide correct information to a withholding agent or broker when QI does not assume primary withholding responsibility for either payment under section 3.02 of this Agreement; or (j) Comply with the requirements of section 8.07 of this Agreement with respect to one or more account holders that are partners holding PTP interests (including account holders of another intermediary when QI acts as an agent for meeting these requirements).

SECTION 11. EXPIRATION, TERMINATION, MERGER AND DEFAULT

**Sec. 11.06. Event of Default. * * *** (B) QI underwithholds a material amount of tax that QI is required to withhold under chapter 3, section 1446(a), section 1446(f), or chapter 4, or backup withhold under section 3406 and fails to correct the underwithholding or to file an amended Form 1042 or 945 reporting, and paying, the appropriate tax;

(E) QI files Forms 945, 1042, 1042-S, 1099, or 8966 that are materially incorrect or fraudulent, or fails to comply materially with the requirements of section 8.07 of this Agreement with respect to account holders that are partners holding PTP interests (including account holders of another intermediary when QI acts as an agent for meeting these requirements).