! statement and transferor documentation applies

CAUTION despite that an NQI may not obtain reduced

withholding on an amount realized it receives from the transfer of a PTP interest.

Alternative procedure for NQIs receiving reportable amounts (and for chapter 4). To use the alternative procedure you must inform the withholding agent on your withholding statement that you are using the procedure, and the withholding agent must agree to the procedure.

Under this procedure, you must provide a withholding agent with all the information required on the withholding statement and all payee documentation, except the specific allocation information for each payee, prior to the payment of a reportable amount. In addition, you must provide the withholding agent with withholding rate pool information. The withholding statement must assign each payee that is not subject to withholding under chapter 4 to a chapter 3 withholding rate pool prior to the payment of a reportable amount. The withholding rate pool may be established by any reasonable method agreed upon by you and the withholding agent. For example, you may agree to establish a separate account for a single withholding rate pool, or you may agree to divide a payment made to a single account into portions allocable to each withholding rate pool. You must determine withholding rate pools based on valid documentation or, to the extent a payment cannot be reliably associated with valid documentation, the applicable presumption rules.

You must provide the withholding agent with sufficient information to allocate the income in each withholding rate pool to each payee (including U.S. exempt recipients) within the pool no later than January 31 of the year following the year of payment. If you fail to provide allocation information, if required, by January 31 for any withholding rate pool, you may not use this procedure for any payment made after that date for all withholding rate pools. You may remedy your failure to provide allocation information by providing the information to the withholding agent no later than February 14. In the case of a reportable amount that is also a withholdable payment, you may include amounts allocable to a chapter 4 withholding rate pool (other than a chapter 4 withholding rate pool of U.S. payees) and payees subject to chapter 4 withholding for whom you will provide payee-specific information in a 30-percent rate pool together with payees subject to chapter 3 withholding at the 30-percent rate and may not otherwise apply these provisions for payments made to U.S. non-exempt recipients (regardless of whether the payment is a withholdable payment). For the amount of the payment allocable to a chapter 4 withholding rate pool of U.S. payees, you may include such an amount in the withholding rate pool that is exempt from withholding (you can include such payees in an exempt pool regardless of whether the payment is a withholdable payment). You must identify prior to the payment each chapter 4 withholding rate pool to be allocated

-18- Instructions for Form W-8IMY (Rev. 10-2021)

a portion of the payment and must also allocate by January 31 the portion of the payment to each such pool in addition to allocating the payment to each other payee as described in the preceding paragraph. See Regulations section 1.1441-1(e)(3)(iv)(D) for further information on alternative procedures for an NQI.

Alternative withholding statement. If a withholding agent agrees, instead of providing a withholding statement that contains all of the information described previously, you may provide an alternative withholding statement for a payment of a reportable amount. You may only use an alternative withholding statement if you are providing the withholding agent with withholding certificates (and not documentary evidence) from the beneficial owners of the payment. The alternative withholding statement is not required to include information that is already on the withholding certificates (including name, address, TIN, chapter 4 status, and GIIN), and you are not required to provide the rate of withholding applicable to each beneficial owner, so long as the withholding agent can determine the appropriate rate based on the withholding certificates. Just as for a nonqualified intermediary withholding statement, the alternative withholding statement must provide information for allocating the payment to each payee and must include any other information the withholding agent needs to fulfill its withholding and reporting obligations.

Line 17e. As part of providing any alternative withholding statements that are associated with your Form W-8IMY, you may make the representation indicated on line 17e. If you check the box line 17e, you are not required to represent on each alternative withholding statement that the information on the withholding certificates provided with the alternative withholding statement is not inconsistent with any other account information you have for the beneficial owners for determining the appropriate rate of withholding. See Regulations section 1.1441-1(e)(3)(iv)(C)(3) for further information on the representation otherwis e required on each alternative withholding statement.