FROM THE OFFICE OF PUBLIC AFFAIRS

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Today, the Treasury Department and the IRS issued technical guidance regarding the information reporting and tax withholding obligations of "qualified intermediaries" and certain foreign partnerships and trusts that make payments of U.S. source income to foreign persons. Revenue Procedure 2004-21 expands the availability of simplified documentation, reporting, and withholding procedures for qualified intermediaries, withholding foreign partnerships, and withholding foreign trusts that were announced last year. In addition, the Revenue Procedure extends until June 30, 2004 the date by which a foreign partnership or foreign trust may apply to be a withholding foreign partnership or trust for 2003 under procedures set forth in Revenue Procedure 2003-64. Finally, the guidance solicits comment on additional ways to improve the qualified intermediary program.

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Related Documents:

• The text of Revenue Procedure 2004-21