The US IRS on January 20 released an updated withholding foreign partnership agreement (WP agreement) and withholding foreign trust agreement (WT agreement).
The agreements, in Revenue Procedure 2017-21, allow foreign partnerships or foreign trusts assume the withholding and reporting obligations for payments of US source income such as interest, dividends, and royalties made to direct partners, beneficiaries, or owners, and in some cases, persons holding interests in the partnership or trust through one or more foreign intermediaries or flow-through entities (indirect partners).
The agreements replace earlier versions provided in Revenue Procedure 2014-47.
The WP and WT agreements in this 2 revenue procedure apply to withholding foreign partnerships (WPs) and withholding foreign trusts (WTs) with a WP or WT agreement effective on or after the date of issuance of this revenue procedure (but see section 12 of the WP or WT agreement for when the terms of the revised WP or WT agreement will apply).
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