Part X (Owner-Documented FFI), line 24. You may

accept this certificate and treat an entity as an owner-documented FFI only if you are a designated withholding agent under the chapter 4 regulations. Also, an owner-documented FFI that is a nonreporting IGA FFI must check “Owner-Documented FFI” (and not “Nonreporting IGA FFI”) on line 5 and complete Part X. You may accept a Form W-8BEN-E from an entity claiming status as an Owner-Documented FFI that does not check box 24d in Part X regardless of whether you know that the entity is a trust that has one or more contingent beneficiaries.

Form W-8ECI You should request Form W-8ECI from any foreign person or organization to which you are making a payment subject to withholding under chapter 3 or 4 if it is the beneficial owner of the income (or an entity engaged in a U.S. trade or business submitting the form on behalf of its owners, partners, or beneficiaries) and claims that the income is effectively connected with the conduct of a trade or business in the United States. However, if you are a partnership (or nominee for a PTP interest), you should

Inst. for the Requester of Forms W-8 (Rev. June 2022) -11-

request a Form W-8BEN or W-8BEN-E (as applicable) from a foreign partner that is allocated income that is ECTI for purposes of withholding under section 1446(a). Nevertheless, a foreign partner that has made an election under section 871(d) or section 882(d) must provide that election to the partnership along with a Form W-8ECI.

An exception from section 1446(f) withholding applies to a foreign dealer that transfers a PTP interest if the foreign dealer provides Form W-8ECI and makes the certifications set forth on line 12 of such form. See Regulations section 1.1446(f)-4(b)(6). You may rely on the certifications made by the dealer for this purpose unless you have actual knowledge they are unreliable or incorrect.

If you receive a Form W-8ECI without a U.S. TIN entered on line 7, you may not rely on Form W-8ECI to treat the income as effectively connected with a U.S. trade or business and you must apply the appropriate presumption rules or obtain another Form W-8 for the payee that you may rely upon. If you receive a Form W-8ECI without an FTIN on line 8a when required and the account holder has not checked line 8b, or provided a reasonable (or other) explanation for why the account holder has not been issued an FTIN on a separate statement when required (see Foreign TINs , earlier), you must treat the form as invalid for payments of U.S. source income reportable on Form 1042-S (as determined before the application of this requirement).

Your receipt of Form W-8ECI serves as a representation by the payee or beneficial owner that the items of income identified on line 11 are effectively connected with the conduct of a trade or business within the United States. Therefore, if a beneficial owner provides you with a Form W-8ECI, you may treat all of the U.S. source income identified on line 11 paid to that beneficial owner as effectively connected with the conduct of a trade or business within the United States and not as a withholdable payment for purposes of chapter 4. Accordingly, a chapter 4 status is not required for a payee who provides a valid Form W-8ECI unless you are an FFI requesting a Form W-8ECI from an account holder for purposes of your chapter 4 due diligence requirements.

If you pay items of income that are not identified on line 11 by the beneficial owner as effectively connected with the conduct of a trade or business within the United States, you are generally required to obtain another type of Form W-8 from the beneficial owner.

Generally, you may not treat an amount otherwise subject to withholding under chapter 3 or 4 as income effectively connected with the conduct of a trade or business within the United States unless the beneficial owner gives you a valid Form W-8ECI. However, there are exceptions (described below) for income paid on notional principal contracts and payments made to certain U.S. branches.

Notional principal contracts reportable on Form 1042-S. Withholding at a 30% rate is not required on amounts paid under the terms of a notional principal contract whether or not a Form W-8ECI is provided (except when a payment made under such contract is U.S. source income, such as a dividend equivalent

amount under section 871(m)). However, if the income is effectively connected with the conduct of a U.S. trade or business, it is reportable by you on Form 1042-S (regardless of whether the payment is U.S. source income). You must treat income as effectively connected with the conduct of a U.S. trade or business, even if a Form W-8ECI has not been received, if the income is paid to a qualified business unit of a foreign person located in the United States or if the income is paid to a qualified business unit of a foreign person located outside the United States and you know, or have reason to know, that the payment is income effectively connected with the conduct of a U.S. trade or business. However, a payment is not treated as income effectively connected with the conduct of a U.S. trade or business if the payee provides a Form W-8BEN-E representing that the payment is not income effectively connected with a U.S. trade or business or makes a representation in a master agreement that governs the transactions in notional principal contracts between the parties (for example, an International Swaps and Derivatives Association agreement), or in the confirmation on the particular notional principal contract transaction, that the payee is a U.S. person or a non-U.S. branch of a foreign person.

Payments to certain U.S. branches treated as effec- tively connected income. If you make a payment to a U.S. branch of a foreign bank or insurance company that does not provide a withholding certificate but has provided an employer identification number (EIN), the payment is presumed to be effectively connected with the conduct of a trade or business within the United States even if the foreign person (or its U.S. branch) does not give you a Form W-8ECI. If you do not obtain a Form W-8ECI or the U.S. branch’s EIN, the income paid cannot be treated as income effectively connected with a U.S. trade or business.

Form W-8EXP You should request Form W-8EXP from any foreign government, international organization, foreign central bank of issue, foreign tax-exempt organization, foreign private foundation, or government of a U.S. possession to which you are making a payment of an amount subject to chapter 3 withholding if such person is claiming an exemption from withholding under sections 1441, 1442, and 1443 pursuant to section 115(2), 501(c), 892, or 895, or claiming a rate of withholding under section 1443(b). Except as provided below, you should request Form W-8EXP from a person claiming an exemption from withholding under chapter 4 as an exempt beneficial owner or tax-exempt organization under section 501(c) or that is claiming any other chapter 4 status shown on the form when also claiming a chapter 3 status described in the preceding sentence. In certain cases, a GIIN may be required based on the chapter 4 status claimed on the form. See Requirements for Obtaining and Verifying a Global Intermediary Identification Number (GIINs) , earlier.

If you are an FFI documenting an account holder that is a tax-exempt organization or exempt beneficial owner (each as defined for chapter 4 purposes) to which you do not pay amounts subject to withholding under chapter 3, you may require that the account holder complete Form

-12- Inst. for the Requester of Forms W-8 (Rev. June 2022)

W-8BEN-E (rather than Form W-8EXP) to establish its status for chapter 4 purposes.

A Form W-8EXP submitted by a foreign person that is a partner in a partnership for purposes of withholding under sections 1441 through 1443 will also establish that partner's foreign status for purposes of section 1446. However, except as provided in Regulations section 1.1446-3(c)(3) (regarding certain tax-exempt organizations described in section 501(c)), the submission of Form W-8EXP will have no effect on whether the partner is subject to withholding under section 1446(a).

You may treat a payee as an international organization without requiring a Form W-8EXP if the payee is designated as an international organization by an executive order (pursuant to 22 U.S.C. 288 through 288(f)) and other facts surrounding the payment reasonably indicate that the beneficial owner of the payment is an international organization. With regard to amounts derived from bankers' acceptances for chapter 3 purposes, you may treat a payee as a foreign central bank of issue without requiring a Form W-8EXP if the name of the payee and other facts surrounding the payment reasonably indicate that the beneficial owner of the payment is a foreign central bank of issue.

A U.S. TIN is required if the beneficial owner is claiming an exemption or reduced rate of withholding based solely on a claim of tax-exempt status under section 501(c) or private foundation status. However, a U.S. TIN is not required from a foreign private foundation that is subject to the 4% excise tax on gross investment income (under section 4948(a)) that would be exempt from withholding except for section 4948(a) (for example, portfolio interest).

If you receive a Form W-8EXP without an FTIN (or a reasonable explanation for why the account holder has not been issued an FTIN) on line 8b (or on a separate statement) when required (see Foreign TINs , earlier), you must treat the form as invalid for payments of U.S. source income reportable on Form 1042-S (as determined before the application of this requirement).

Form W-8IMY For purposes of chapter 3 and 4, you should request Form W-8IMY from any entity that is a QI (including a QI acting as a QDD), an NQI (including certain U.S. branches and territory financial institutions), a withholding foreign partnership (WP), a withholding foreign trust (WT), or a flow-through entity to which you make a withholdable payment or pay a reportable amount. A flow-through entity for purposes of chapters 3 and 4 includes a foreign partnership (other than a WP), a foreign simple or grantor trust (other than a WT), and, for any payments for which a treaty benefit is claimed, any entity to the extent it is treated as fiscally transparent under the laws of the treaty jurisdiction, as provided in section 894 and the regulations thereunder (without regard to whether it is fiscally transparent under the laws of the United States). See Section 1446 Requirements, later, for when an intermediary, partnership or trust is required to provide a Form W-8IMY for purposes of sections 1446(a) and (f). As provided in Notice 2020-2, Form W-8IMY may also be provided by an entity to claim chapter 3 status as a QSL

with respect to payments of U.S. source substitute dividends made in 2022 and may be relied upon regardless of whether the QSL acts as an intermediary with respect to substitute dividends associated with the form. You may accept a Form W-8IMY from an individual acting as an agent or intermediary (as appropriately amended to account for individual status), but you are not required to obtain such form if you are able to associate payments you make to the person(s) for whom the individual acts.

You may accept multiple Forms W-8IMY from an intermediary that is acting in multiple capacities (for example, as a QI for one account but an NQI or QDD for another account). However, a QI may provide you with a single Form W-8IMY that covers more than one category of QI shown on the form, provided that it properly identifies to you the accounts and/or transactions on a withholding statement. Thus, for example, a QI may provide a single Form W-8IMY when acting as both an intermediary and as a QDD with respect to payments you make to the QI (by checking each applicable box in Part III of the form). You may accept a single Form W-8IMY, including a withholding statement with the required information. For multiple branches of the entity providing the form if the information in Part I is the same for each branch and a separate schedule is attached that includes all of the Part II information on each branch and sufficient information to associate the payments with each branch and any other required information.

The chapter 4 status of an intermediary or flow-through entity is required on Part I of the form if the form is associated with a withholdable payment. Part II must be completed when a withholdable payment is made to a branch or disregarded entity described in Part II of the form.

Generally, for purposes of both chapters 3 and 4, except to the extent otherwise provided in the Regulations under section 1441 or 1471, a Form W-8IMY must be associated with a withholding statement and withholding certificates (or documentary evidence, where permitted) for the beneficial owners. Generally, the withholding statement must allocate the payment to each payee (or pool of payees, where permitted, as described later), provide the rate of withholding for each payee (or pool of payees), and provide certain identification information on each payee that is not included in a pool. See, however, Regulations section 1.1441-1(e)(3)(iv)(C)(3) for the allowance for a withholding agent to accept an alternative withholding statement from an NQI (which also applies to a flow-through entity) for purposes of chapter 3 or 4. Also see the Instructions for Form W-8IMY for information on the box that an NQI may check on the form when providing an alternative withholding statement.

If you are a participating FFI or registered deemed-compliant FFI, you may also request Form W-8IMY from an intermediary or flow-through entity that is an account holder to establish its chapter 4 status or status under an applicable IGA even when no payments subject to withholding or domestic information reporting under chapter 61 are made to the account. In such a case, a withholding statement is not required.

Inst. for the Requester of Forms W-8 (Rev. June 2022) -13-

Notes for Validating Form W-8IMY

In addition to the validation requirements for Forms W-8IMY described directly below with respect to QIs (including QDDs), flow-through entities, NQIs, U.S. branches, territory financial institutions, and QSLs providing the form (requirements that apply for chapters 3 and 4 and Form 1099 reporting), see Section 1446 Requirements, later, if you pay an amount realized or an amount distributed by a PTP (PTP distribution) to any of these entities, or are otherwise a partnership determining its withholding under section 1446(a).

QIs, WPs, and WTs (in general). A QI, WP, or WT acting in its capacity as such must provide the EIN that was issued to the entity in such capacity (that is, its QI-EIN, WP-EIN, or WT-EIN) on Form W-8IMY and not any other EIN it may have in its NQI, nonwithholding foreign partnership, or nonwithholding foreign trust capacity. Because status as a QI, WP, or WT for a financial institution is limited to certain classes of FFIs, if you are making a withholdable payment to a QI, WP, or WT that is a financial institution, you must verify that the QI, WP, or WT certifies its status as one of the permitted classes in Regulations sections 1.1441-1(e)(5)(ii) (for a QI), 1.1441-5(c)(2)(ii) (for a WP), or 1.1441-5(e)(5)(v) (for a WT) and provides its GIIN (except in the case of certain foreign central banks of issue and retirement funds).

If a QI checks line 15f of Part III of the form to certify that it assumes primary Form 1099 reporting and backup withholding responsibility, you may accept the form even if you do not know if there are any U.S. accounts receiving reportable payments at the time of the certification. If a QI does not check line 15f or 15g of Part III of the form, you must confirm that the QI is not receiving payments for U.S. accounts that are reportable on Form 1099, and the QI must provide an updated Form W-8IMY or must provide a withholding statement if it allocates payments to such accounts for which it does not assume primary withholding responsibility. A QI may check line 15i of Part III of the form to indicate that it allocates a portion of the payment to a chapter 4 withholding rate pool of U.S. payees that includes account holders of another intermediary or flow-through entity even if the withholding statement does not show any intermediaries or flow-through entities at the time the certification is provided. However, a QI is not required to check line 15i of Part III of the form until it provides a withholding statement identifying an intermediary or flow-through entity that receives a payment allocated to a chapter 4 withholding rate pool of U.S. payees.

QIs acting as QDDs. You should only accept a Form W-8IMY from a QI acting as a QDD to the extent you are making payments with respect to potential section 871(m) transactions or underlying securities to the QDD when the entity claims QDD status in Part III of the form. A QDD must indicate its entity classification on line 16b of the form. If you are making such payment that is an amount subject to chapter 3 withholding to a QI that is acting as a QDD and the QDD is claiming treaty benefits applicable to the status identified on line 16b on the payment, you may treat the Form W-8IMY as a beneficial owner withholding certificate and provide such benefits if the QDD provides a statement associated to the Form W-8IMY that includes

the necessary information with respect to the treaty claim required in Part III of Form W-8BEN-E and its FTIN (when otherwise required) on a QDD withholding statement or separate statement. In such case, the portion of the certificate making a claim for treaty benefits is valid until the end of the third calendar year following the year in which the Form W-8IMY is signed (unless a change in circumstances occurs sooner), and the validation rules for a treaty claim apply. A QDD may instead provide a separate Form W-8BEN-E to make the treaty claim. You may otherwise treat a Form W-8IMY provided by a QDD (other than a flow-through entity or disregarded entity) as a beneficial owner withholding certificate for establishing foreign status of the QDD for a payment of U.S. source FDAP income (as long as the QDD provides its FTIN (when otherwise required) on a QDD withholding statement or a separate statement). A QDD that is receiving payments that it beneficially owns that are not covered by its QI agreement should provide the appropriate Form W-8 based on its status (and not Form W-8IMY). The QDD must provide to you a withholding statement to identify the home office or branch that is treated as the owner for U.S. income tax purposes and, in certain circumstances (described in the Instructions for Form W-8IMY), the QDD’s FTIN (or a reasonable explanation for why it has not been issued an FTIN, if required). Notwithstanding the preceding sentence, a QDD withholding statement need not identify the branch or home office of the QDD if the form is provided only for payments beneficially owned by the QDD (and an FTIN is provided when required). See Foreign TINs, earlier, for when you must treat the form as invalid if an FTIN or reasonable explanation is not provided.

QIs assuming withholding on payments of substitute interest. If a QI represents its status as a QI on a Form W-8IMY with respect to payments of interest and substitute interest and checks line 15e of Part III of the form, you may treat the QI as assuming withholding for payments of interest and substitute interest it receives from you in connection with a sale-repurchase or similar agreement, a securities lending transaction, or collateral that the QI holds in connection with its activities as a dealer in securities. You may accept this representation regardless of whether the QI represents it acts as a QDD (by checking line 16a in Part III). The representation on Line 15e does not apply to payments made to a QI when acting as a QDD.

QSLs. If you make payment of a U.S. source substitute dividend to a QSL (prior to January 1, 2023), the QSL is required to provide its U.S. TIN. If you make a payment to a QSL (prior to January 1, 2023) that is a withholdable payment, you must collect a Form W-8IMY that includes the QSL’s chapter 4 status and GIIN (as applicable) to avoid withholding under chapter 4. A QSL that is a QI should check line 15d of Part III of the form and a QSL that is an NQI should check line 17d of Part IV of the form regardless of whether the QSL acts as an intermediary. You may not associate a Form W-8IMY from a QSL with a payment of a substitute dividend on or after January 1, 2023, and you should obtain a revised withholding certificate.

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For information on transition rules that apply until 2023 for withholding agents to apply with respect to QSLs, see Notice 2020-2 .

U.S. branches. If you make a payment to a U.S. branch of a foreign bank or insurance company that represents that it is acting as an intermediary and has agreed to be treated as a U.S. person, for chapter 3 and 4 for payments associated with this form (by checking line 19a in Part VI of this form) you are not required to obtain the GIIN or chapter 4 status of the entity, but you must obtain the U.S. branch’s EIN. If you make a withholdable payment to a U.S. branch of an FFI that is acting as an intermediary and that does not agree to be treated as a U.S. person, the branch must provide its EIN (but does not need to provide a GIIN or chapter 4 status) and certify that the branch is applying the rules described in Regulations section 1.1471-4(d)(2)(iii)(C) by checking the box on line 19c in Part VI of the form. If you do not obtain the certification from a U.S. branch described in the preceding sentence, you must treat the branch as a nonparticipating FFI and withhold under chapter 4 on withholdable payments made to the branch. You are not required to treat as invalid a Form W-8IMY from an account holder that completes Part VI of the form (to the extent required) but does not complete Part II of the form.

Territory financial institutions acting as intermedia- ries. If you make a payment to a territory financial institution acting as an intermediary, you must obtain the territory financial institution’s EIN if it agrees to be treated as a U.S. person for chapters 3 and 4 for payments associated with this form (by checking line 18b of Part V of the form). You are not required to obtain a GIIN from a territory financial institution.

Participating FFIs and registered deemed-compliant FFIs that are flow-through entities or acting as inter- mediaries. If a participating FFI or registered deemed-compliant FFI that is an intermediary or flow-through entity provides you with a withholding statement and documentation for its account holders or payees, you are not required to verify the information on the account holders or payees provided in the documentation for chapter 4 purposes unless the information in the documentation is facially incorrect, and you are not required to obtain additional documentation for an account holder or payee in addition to the withholding certificate unless you are obtaining the documentation for purposes of chapter 3 or 61, or unless you know that the documentation review conducted by the participating FFI or registered deemed-compliant FFI was not adequate for purposes of chapter 4. See Regulations section 1.1441-7(b)(10) for the due diligence requirements for indirect account holders for purposes of chapter 3 and see Regulations section 1.1471-3(e)(4)(vi) (B) for standards that apply in such case to determine whether chapter 4 withholding applies. You may rely on documentation that does not include a chapter 4 status for an account holder of an intermediary or flow-through entity that is an FFI when the withholding statement provided by such entity indicates that the payment is made to an account excluded as a financial account under Regulations section 1.1471-5(b)(2).

An intermediary or flow-through entity that is a participating FFI or registered deemed-compliant FFI may provide a status for chapter 4 purposes found under the requirements of (and documentation or information that is publicly available that determines the chapter 4 status of the payee permitted under) an applicable IGA for an account holder, and you may rely upon such status and documentation, provided that you have the information necessary to report on Form 1042-S. Additionally, see Alternative Certifications Under an Applicable IGA, earlier, for further details on alternative certifications.

In general, if you make a withholdable payment to an intermediary or flow-through entity that is a participating FFI or registered deemed-compliant FFI, the FFI may provide an FFI withholding statement that allocates a portion of the payment to a chapter 4 withholding rate pool. If an intermediary provides with its Form W-8IMY an FFI withholding statement that allocates a portion of the payment to a chapter 4 withholding rate pool of U.S. payees, the FFI must provide a chapter 4 status on line 5. If the intermediary described in the preceding sentence is an NQI, it must provide the certification required in Part IV with respect to its compliance with the requirements of Regulations section 1.6049-4(c)(4) (or similar requirements under chapter 61 for a payment other than interest). If the intermediary is a QI, it must certify that it meets the requirements of Regulations section 1.6049-4(c)(4)(iii) and, to the extent the U.S. payees are account holders of an intermediary or flow-through entity receiving a payment from the QI, the QI has obtained or will obtain documentation sufficient to establish each such intermediary or flow-through entity status as a participating FFI, registered deemed-compliant FFI, or FFI that is a QI. An allocation of a payment shown on a withholding statement and made on or after April 1, 2017, to an NQI, nonwithholding foreign partnership, or nonwithholding foreign trust of an amount subject to chapter 3 withholding to a chapter 4 withholding rate pool of U.S. payees must identify the payees consistent with the description in Regulations section 1.1471-3(c)(3)(iii) (B)(2)(iii) (describing account holders of an FFI that is a non-U.S. payor that are not subject to withholding under chapter 3 or 4 or under section 3406, and that are holders of U.S. accounts reported by the FFI under its Foreign Account Tax Compliance Act (FATCA) requirements as a participating FFI or registered deemed-compliant FFI).

Section 1446 Requirements

Section 1446(a) requirements in general. You should request Form W-8IMY for purposes of section 1446(a) only from a foreign upper-tier partnership or foreign grantor trust or from a simple trust if you do not obtain a Form W-8BEN-E from the trust. You may also accept a Form W-8IMY from a foreign intermediary holding a partnership interest for a partner (including a partner that is an upper-tier partnership or trust) for determining your withholding under section 1446(a). Generally, for purposes of section 1446(a), the Form W-8IMY submitted by these entities is used to transmit the forms of the owners of these entities (excluding a partnership that is a PTP and a simple trust when a Form W-8IMY is provided). The other forms should be accompanied with the information necessary to reliably

Inst. for the Requester of Forms W-8 (Rev. June 2022) -15-

associate your effectively connected partnership items with the upper-tier partners, in the case of a foreign upper-tier partnership, and the grantor or other owner, in the case of a foreign grantor trust. Then you must look through these entities to the beneficial owners when determining your section 1446(a) tax obligation. A domestic upper-tier partnership may also provide you this information by attaching it to a Form W-9 with a statement that it is electing to apply these look through rules. Under those circumstances you may, but are not required to, pay the section 1446(a) withholding tax of the foreign partners of the domestic upper-tier partnership. See Regulations section 1.1446-5.

Section 1446(a) (PTP Distributions). Notwithstanding the preceding paragraph, for an amount subject to section 1446(a) withholding on a PTP distribution, you may accept a Form W-8IMY from a QI that acts as a nominee for the distribution by checking lines 14 and 15c. In such a case, you must treat the QI as assuming all withholding on the distribution (that is, amounts subject to chapters 3 and 4 withholding on the distribution in addition to amounts subject to sections 1446(a) and (f) withholding on the distribution). You may accept this representation regardless of whether the QI assumes primary withholding for other payments subject to chapters 3 and 4 withholding by checking line 15a. You may also accept a Form W-8IMY that is associated with a PTP distribution from any entity that represents its status as a QI on line 14 but that does not check line 15c for purposes of your relying on chapters 3 and 4 withholding rate pool information provided by the QI (similar to a case in which a QI does not assume primary withholding for chapters 3 and 4 purposes except that each U.S. partner must be disclosed). A QI that represents its status as a QI on line 14 of a Form W-8IMY that is associated with a PTP distribution may instead, however, act as a disclosing QI for the distribution by not acting as a nominee and providing specific payee information to you with its withholding statement with respect to its account holders that are partners in the PTP (and may only provide chapter 4 withholding rate pool information when permitted under chapter 4 for a withholdable payment). You may not, however, rely on an allocation of a PTP distribution made to a chapter 4 withholding rate pool of U.S. payees (that is, each U.S. partner must be disclosed). Regardless of whether the QI acts as a disclosing QI, you must determine each amount subject to withholding on the PTP distribution by reference to the qualified notice issued for the distribution (or, if you receive the distribution from a nominee, the nominee's determination) rather than relying on a determination of those amounts by the QI (to avoid withholding under the default rule in Regulations section 1.1446-4).

If the entity checks its status as an NQI in box 17a of Part IV, you must treat the entity as an NQI for a PTP distribution that is associated with the form. For determining your withholding on the distribution, you may rely on specific payee information provided by the NQI with respect to the partners allocated the distribution on a withholding statement provided with the form and chapter 4 withholding rate pool information to the extent permitted for a QI (as described directly above), but may not rely on that information and withholding statement for

purposes of withholding on an amount realized on the distribution (that is, you must withhold at the 10% rate on an amount to which section 1446(f) applies without regard to underlying payee information).

You may also accept a Form W-8IMY that is associated with a PTP distribution from a U.S. branch that acts as nominee for a PTP distribution by checking line 19e. If the U.S. branch does not act as a nominee for the distribution by checking line 19f, you may rely on specific payee documentation provided by the U.S. branch with the form to the same extent described in the preceding paragraph with respect to an NQI to which you pay a PTP distribution. You must apply similar rules in the case of a Form W-8IMY associated with the distribution that is provided by a territory financial institution.

Although you may accept a Form W-8IMY that is associated from a PTP distribution from an entity that represents its status as a WP or WT, you may not treat the entity as a WP or WT except for the amount of the distribution subject to withholding under chapter 3 or 4. For a nonwithholding partnership or trust to which you pay a PTP distribution that checks line 21b, see Section 1446 Requirements , earlier. See the requirements of chapters 3, 4 and section 1446(f) for when you can rely on partner, owner or beneficiary information for amounts subject to withholding under those provisions on a PTP distribution.

Section 1446(f) (PTP interest transfer). For purposes of section 1446(f), you should request a Form W-8IMY from a partner that is a foreign partnership that transfers an interest in a partnership if you are either the transferee of the interest (for a partnership other than a PTP) or a broker for the partner that sells a PTP interest. You should request the Form W-8IMY from the foreign partnership regardless of whether the partnership provides with the form the partner information for allowing withholding on a modified amount realized under Regulations section 1.1446(f)-2(c) or 1.1446(f)-4(c). See the Instructions for Form W-8IMY for requirements regarding a withholding statement for purposes of the modified amount realized procedures (which requires a withholding statement allocating gain from the transfer). For a partner that is a foreign grantor trust, you should request a Form W-8IMY from the trust and either a Form W-8 or W-9 with respect to each grantor or owner of the trust (as the grantor/owner is the transferor). Alternatively, you may request the Form W-8 or W-9 directly from each grantor or owner. For a partner that is a foreign simple trust, you may request either a Form W-8IMY or W-8BEN-E from the trust; you do not need to request a withholding statement or underlying documentation for the trust beneficiaries, however, as the simple trust is the transferor and may not use the modified amount realized procedures described earlier in this paragraph.

If you are a broker paying an amount realized from the sale of a PTP interest to a broker that is a foreign person, you should request a Form W-8IMY from the broker when withholding under section 1446(f) may apply (or otherwise obtain a Form W-9 from a U.S. broker when required). If the foreign broker is a QI (by checking line 14), you may accept a Form W-8IMY when the QI represents that it assumes primary withholding for the amount realized by checking line 15b. You may also accept a Form W-8IMY

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that is associated with an amount realized from the sale of a PTP interest from any entity that represents its status as a QI on line 14 that does not check line 15c for purposes of relying on chapter 3 withholding rate pool information provided by the QI (similar to a case in which a QI does not assume primary withholding for a PTP distribution). You may instead rely on specific payee information provided by a QI that acts as a disclosing QI for an amount realized (or a chapter 4 withholding rate pool when permitted for chapter 4). If the foreign broker is an NQI, you may accept a Form W-8IMY associated with an amount realized when the NQI checks box 17a, although you must determine your withholding under section 1446(f) without regard to whether the NQI provides specific payee information with respect to the partners allocated the amount. See the Instructions for Form W-8IMY for when you may rely on payee information provided by an NQI solely for purposes of reporting on the payees on Form 1042-S. This same withholding requirement (and reporting allowance) applies to a broker that is a U.S. branch or territory financial institution that provides a Form W-8IMY for an amount realized from the sale of a PTP interest and does not act as a U.S. person for the amount by checking line 19d (for a U.S. branch) or line 18d (for a territory financial institution).

In the case of a PTP distribution, you need not

TIP withhold under section 1446(f) in any case

described in Section 1446(a) (PTP distributions) above (or on any other transferor) when the PTP does not indicate on the qualified notice for the distribution an amount that is in excess of its cumulative net income. See Regulations section 1.1446(f)-4(c)(2). See, however, Regulations section 1.1446-4(d)(1) for withholding requirements when a nominee does not receive a qualified notice or the notice does not specify an amount included in a distribution.

Requirements for Hybrid and Reverse Hybrid Entities A hybrid entity is an entity that is treated as fiscally transparent under the Code but is not treated as fiscally transparent under the tax laws of a country with which the United States has an income tax treaty.

If you are making a payment to a foreign hybrid entity that is making a claim for treaty benefits on its own behalf, the hybrid entity should provide a Form W-8BEN-E to claim treaty benefits. If the hybrid entity is a flow-through entity (not a disregarded entity) claiming treaty benefits on its own behalf on a payment that is a withholdable payment, it should also provide you a Form W-8IMY (including its chapter 4 status) along with a withholding statement (if required) establishing the chapter 4 status of each of its partners or owners to determine whether withholding applies to any portion of the payment. Allocation information is not required on this withholding statement unless one or more partners or owners are subject to chapter 4 withholding. If the hybrid entity is a disregarded entity claiming treaty benefits on a payment that is a withholdable payment, unless the disregarded entity is treated as the payee for chapter 4 purposes and has its own GIIN, the single owner should provide a Form W-8BEN-E or Form W-8BEN (as applicable) to you along

with the Form W-8BEN-E for the hybrid entity. Line 10 of the Form W-8BEN-E may be used by the hybrid entity to associate the Forms W-8.

A foreign reverse hybrid entity is an entity that is a corporation for U.S. tax purposes but is fiscally transparent under the tax laws of a country with which the United States has an income tax treaty. If a foreign reverse hybrid entity is receiving a payment for which the entity is claiming a reduced rate of withholding for its owners, you must obtain from the entity a Form W-8IMY (including its chapter 4 status if the payment is a withholdable payment) along with a withholding statement and documentation for each owner for which the entity claims treaty benefits. If a foreign reverse hybrid entity is receiving a withholdable payment and is not claiming treaty benefits on behalf of any of its owners, you should obtain only a Form W-8BEN-E from the entity to establish its chapter 4 status.

You may develop and use your own Form W-8 (a substitute form) for chapters 3 and 4 purposes and for section 1446(a) and (f) purposes if its content is substantially similar to the IRS's official Form W-8 (to the extent required by these instructions), it satisfies certain certification requirements, and it includes a signature under a penalties of perjury statement that is identical to the one stated on the official form. You may develop and use a substitute form that is in a foreign language, provided that you make an English translation of the form and its contents available to the IRS upon request. You may combine multiple Forms W-8 into a single substitute form.

A form that satisfies these substitute forms requirements may be treated as a similar agreed form for purposes of an applicable IGA unless the partner jurisdiction declines such treatment.

A substitute form does not need to contain all of the provisions contained on the official form, so long as it contains those provisions that are relevant to the transaction for which it is furnished. You may omit the chapter 4 certifications on your substitute form if such certifications are not required based on the payments made to the payees. If you are an FFI documenting the chapter 4 status of your account holders under your chapter 4 requirements or an applicable IGA, however, you may not omit the chapter 4 certifications. If you are making a withholdable payment, you may choose to provide a substitute form that does not include all of the chapter 4 statuses provided on the Form W-8, but the substitute form must include any chapter 4 status for which withholding may apply.

You may incorporate a substitute Form W-8 into other business forms you customarily use, such as account signature cards, provided the required certifications are clearly set forth. However, you may not:

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1. Use a substitute form that requires the payee, by signing, to agree to provisions unrelated to the required certifications; or

2. Imply that a person may be subject to 30% withholding or backup withholding unless that person agrees to provisions on the substitute form that are unrelated to the required certifications.

A substitute Form W-8 is valid only if it contains the same penalties of perjury statement and certifications as the official forms and the required signature. However, if the substitute form is contained in some other business form, the words “information on this form” may be modified to refer to that portion of the business form containing the substitute form information. The design of the substitute form must be such that the information and certifications that are being attested to by the penalties of perjury statement clearly stand out from any other information contained in the form.

Content of Substitute Form

Substitute Form W-8BEN. The substitute Form W-8BEN must contain all of the information required in Part I, lines 1 through 8. The certifications in Part II must be included in a substitute form only if treaty benefits are claimed, and then only to the extent that the certifications are required. For example, Form W-8BEN, line 10 (Special rates and conditions), is not required if the form is being requested from an individual receiving a payment of U.S. source dividends from stocks that are actively traded on an established securities market. The substitute Form W-8BEN must include a statement that if the person providing the form is a resident in a FATCA partner jurisdiction (that is, a Model 1 IGA jurisdiction with reciprocity), certain tax account information may be provided to the jurisdiction of residence.

The substitute form must contain the penalties of perjury statement identical to the statement on the official Form W-8BEN. Additionally, if the substitute form is incorporated into other business forms, the following statement must be presented in the same manner as the penalties of perjury statement and must appear immediately above the single signature line: “The Internal Revenue Service does not require your consent to any provisions of this document other than the certifications required to establish your status as a non-U.S. individual and, if applicable, obtain a reduced rate of withholding.”

Substitute Form W-8BEN-E. The substitute Form W-8BEN-E must contain all of the information required in Part I, lines 1 through 6, and lines 8 and 9 if a U.S. or an FTIN or a GIIN is required. See, however, Substitute Forms W-8 for Payments of Reportable Amounts and Withholdable Payments , earlier, for when you may omit a chapter 4 certification on a substitute Form W-8. The certifications in Part II must be included in a substitute form if you are making a withholdable payment to a disregarded entity or a branch that must be reported in Part II. The certifications in Part III must be included only if treaty benefits are claimed, and then only to the extent that the certifications are required. See Alternative Certifications Under an Applicable IGA , earlier, for circumstances in which the chapter 4 certifications may be replaced with alternative certifications.

If the substitute form is incorporated into other business forms, the following statement must be presented in the same manner as the penalties of perjury statement and must appear immediately above the single signature line: “The Internal Revenue Service does not require your consent to any provisions of this document other than the certifications required to establish your status as a non-U.S. person, establish your chapter 4 status (if required), and, if applicable, obtain a reduced rate of withholding.”

Substitute Form W-8ECI. The substitute Form W-8ECI must contain all of the information required in Part I other than line 9. The certifications in Part II of Form W-8ECI must be included in a substitute form.

If the substitute form is incorporated into other business forms, the following statement must be presented in the same manner as the penalties of perjury statement and must appear immediately above the single signature line: “The Internal Revenue Service does not require your consent to any provisions of this document other than the certifications required to establish your status as a non-U.S. person and that the income for which this form is provided is effectively connected with the conduct of a trade or business within the United States.”

Substitute Form W-8EXP. The substitute Form W-8EXP must contain all of the information required in Part I, lines 1 through 5, line 7 (if a U.S. TIN is required), and line 8. See, however, Substitute Forms W-8 for Payments of Reportable Amounts and Withholdable Payments , earlier, for when you may omit a chapter 4 certification on a substitute Form W-8. The substitute Form W-8EXP must also contain all of the statements and certifications contained in Parts II and III, as applicable, with respect to the purpose for which the form is provided, but a specific statement or certification needs to be included (in its entirety) only if it is relevant to the type of entity providing the form. For example, if a withholding agent is documenting a beneficial owner that is a foreign government for purposes of both chapters 3 and 4, the withholding agent may use a substitute Form W-8EXP that contains the required information in Part I, plus the required statements and certifications from Parts II and III that are related to foreign governments, and does not need to include the statements and certifications for other types of entities that would otherwise be providing the Form W-8EXP.

If the substitute form is incorporated into other business forms, the following statement must be presented in the same manner as the penalties of perjury statement and must appear immediately above the single signature line: “The Internal Revenue Service does not require your consent to any provisions of this document other than the certifications required to establish your status as a foreign government, international organization, foreign central bank of issue, foreign tax-exempt organization, foreign private foundation, or government of a U.S. possession, and your chapter 4 status (if required).”

Substitute Form W-8IMY. The substitute Form W-8IMY must contain all of the information required in Part I, lines 1 through 6, line 8 (if a U.S. TIN is required), and line 9 (if a GIIN is required). See, however, Substitute Forms W-8

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for Payments of Reportable Amounts and Withholdable Payments , earlier, for when you may omit a chapter 4 certification on a substitute Form W-8. The information required in Part II must be included in a substitute form if you are making a withholdable payment to a disregarded entity that has its own GIIN or a branch (including a branch that is a disregarded entity that does not have its own GIIN) operating in a jurisdiction other than the jurisdiction of residence of the entity named in Part I of the form. The substitute Form W-8IMY must also contain all of the statements and certifications relevant to chapter 3 contained in Parts III through VIII if you are making a payment subject to withholding under chapter 3 and the statements and certifications relevant to the chapter 4 status contained in Parts IX through XXVIII for the intermediary or flow-through entity providing the form if you are making a withholdable payment or if you are an FFI documenting your account holders for purposes of chapter 4 or an applicable IGA. For example, if the only intermediaries to which a U.S. withholding agent makes payments are QIs that are participating FFIs, the withholding agent may use a substitute Form W-8IMY that contains only the required information from Part I (including line 9 to collect the intermediaries’ GIINs), plus the statements and certifications from Part III. A substitute Form W-8IMY must also incorporate the same attachments as the official form (such as a withholding statement and beneficial owner documentation, to the extent otherwise required). You may also include any information on a substitute Form W-8IMY, or require any information to be associated with the form, that is reasonably related to your obligation to withhold and correctly report payments.

If the substitute form is incorporated into other business forms, the following statement must be presented in the same manner as the penalties of perjury statement and must appear immediately above the single signature line: “The Internal Revenue Service does not require your consent to any provisions of this document other than the certifications required to establish: (1) your status as a QI,

an NQI, a specific type of U.S. branch, a withholding foreign partnership, a withholding foreign trust, a nonwithholding foreign partnership, a nonwithholding foreign simple trust, or a nonwithholding foreign grantor trust; (2) your chapter 4 status; and/or (3) your status as a QSL (for the period such status is permitted).”

Non-IRS Form for Individuals Not Receiving Reportable Amounts If you are an FFI documenting an account holder that is an individual and you are not making a payment of a reportable amount to such account holder, you may use a non-IRS form rather than a substitute Form W-8BEN. The form must include the name and address of the individual that is the payee or beneficial owner; all countries in which the individual is resident for tax purposes; the individual’s country of birth; a TIN, if any, for each country of residence; and the individual’s date of birth. The form may also request other information required for purposes of tax or anti-money laundering (AML) due diligence in the United States or in other countries. A form that satisfies these requirements may be treated as a similar agreed form for purposes of an applicable IGA unless the partner jurisdiction declines such treatment.

Generally, a non-IRS form for individuals must contain a signed and dated certification made under penalties of perjury that the information provided on the form is accurate and will be updated by the individual within 30 days of a change in circumstances that causes the form to become incorrect. However, the signed certification provided on a form need not be signed under penalties of perjury if the form is accompanied by documentary evidence that supports the individual’s claim of foreign status. Such documentary evidence may be the same documentary evidence that is used to support foreign status in the case of a payee whose account has U.S. indicia as described in Regulations sections 1.1471-3(e) and 1.1471-4(c)(4)(i)(A).

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