The IRS issued Notice 2011-34 on Friday, April 8, to provide guidance in response to certain priority concerns identified by commentators following the publication of Notice 2010-60. See
For an electronic version of the notice:
The following is an initial analysis of the provisions included in Notice 2011-34.
In an effort to curb perceived tax abuses by U.S. persons with offshore bank accounts and/or investments, Congress passed broad, sweeping legislation intended to combat offshore tax evasion by such persons. Specifically, the Foreign Account Tax Compliance Act (FATCA), signed into law on March 18, 2010, as part of the
Hiring Incentives to Restore Employment Act, adds a new chapter 4 withholding regime to the Code that is designed to achieve this stated intent by imposing a penal withholding tax on certain foreign entities that refuse to disclose the identities of these U.S. persons.
The effective date for the new regime is January 1, 2013, with certain grandfather provisions for debt obligations that are outstanding two years from the date of enactment.
The statute, while providing very general information with respect to the new withholding regime, defers the details and implementation of the new regime to Treasury and the IRS. Though proposed regulations outlining these new requirements are not expected for some time, Notice 2010-60 was released in August 2010, setting forth the general framework that Treasury and the IRS intend to follow when implementing the new
chapter 4 withholding regime.
Last Friday, April 8, 2011, a second notice—Notice 2011-34—was released to provide guidance in response to certain priority concerns identified by commentators following the publication of Notice 2010-60. As with the first notice, Notice 2011-34 also requests further comments with respect to specific issues.
The key priority issues set forth in Notice 2011-34, which are described in more detail below, include:
I. Procedures that participating foreign financial institutions (FFIs) are to follow in identifying U.S. accounts among their pre-existing individual accounts
II. Guidance on the definition of “passthru payment” and the obligation of FFIs to withhold on passthru payments
III. Guidance on certain categories of FFIs that are deemed compliant
IV. Guidance on the obligation of FFIs to report with respect to U.S. accounts
V. Rules for the treatment of qualified intermediaries under section 1471
VI. Guidance for application of section 1471 to expanded affiliated groups of FFIs
VII. The effective date of FFI Agreements
I. Preexisting Individual Accounts
Section I of Notice 2011-34 modifies the rules set forth in Notice 2010-60 that a participating FFI must employ to identify a U.S. account among its preexisting individual accounts. Pursuant to the new requirements, the FFI must treat an account holder as a U.S. person if it already has documentation on file that identifies the account holder as a specified U.S. person. Note, however, that
any account with a balance that does not exceed $50,000 at the end of the calendar year prior to the effective date of the FFI Agreement can be treated as a non-U.S. account. The statute and Notice 2010-60 limited this relief to deposit accounts only.
Significantly, for purposes of determining account balances, the FFI will be required to treat all accounts maintained by the FFI and its affiliates as a single account to the extent such accounts are associated with each other, due to partial or complete common ownership of accounts under the FFI’s existing computerized system for information management, accounting, tax reporting, tax, and accounting reporting, or other recordkeeping systems. Also, for joint accounts, the entire balance of an account will be attributed to a joint owner for purposes of this determination.
Tax professionals have noted that the requirements in Notice 2011-34 for aggregating account balances are limited to those financial institutions whose current computer systems are able to partially or completely match such data for other purposes. It appears that this account-coordination requirement is adopted from Reg. section 1.1441-1(e)(ix), in which a withholding agent can share documentation among group members when the members share a coordinated account system.
The rules that permit the use of shared documentation, however, specifically require the use of a universal account system. Thus, the IRS will not permit a withholding agent to share data unless there is a single system where the data can be “easily access[ed].” Conversely, the rule here seems to require account aggregation even when a system is only partially linked. As a result, the de minimus exception may be unworkable for many FFIs.
Specifically, it has been reported by several FFIs that they believe the requirement to monitor all accounts throughout its organization—especially when the linkage between various members’ systems is not complete—will be too onerous. As a result, it is anticipated that many FFIs may conclude they have no choice but to forego this relief.
Notice 2011-34 also provides a new set of requirements for private banking accounts.
Very generally, a private banking account is any account maintained by an FFI’s private banking department. If such accounts have not already been identified as U.S. accounts based on documentation already on file, or excluded under the de minimus exception, very specific rules are imparted upon the FFI and the relevant account relationship manager for each such account.
Specifically, the FFI must require that the account relationship manager identifies all accounts under its management when it has actual knowledge of U.S. ownership and request a Form W-9 from all U.S. identified account holders. When such actual knowledge is not present, the manager must review the account information (paper and electronic) to determine whether, to the best of the manager’s knowledge, the client or any associated family members have status as a U.S. citizen or green card holder, a U.S. birthplace, a U.S. residence or mailing address (including a U.S. post office box (P.O. Box)), standing instructions to transfer funds to a U.S. account, or directions regularly received from the United States, an “in care of” or “hold mail” address as the only address, or a power of attorney granted to a person with a U.S. address.
When such information exits, the manager must request a Form W-9 (and a waiver permitting the FFI to disclose). If the account holder claims not to be a U.S. person, the manger must request a Form W-8BEN and/or documentary evidence and, in certain instances (e.g., a U.S. birthplace), a written explanation to cure the indicia of potential U.S. status that was identified. If such curative documentation is not obtained, the FFI must treat the account—and all accounts associated with the client—as U.S. accounts and either report to the IRS or treat the account holder as recalcitrant within one year of the U.S. indicia discovery.
Note, however, if a family member of the account holder has provided a Form W-8BEN and documentary evidence establishing foreign status with respect to another account, the account will not be treated as U.S. unless the manager knows or has reason to know the family member is acting as a nominee or agent for the identified U.S. client. In addition to the above, the manager must create and retain a list of all existing clients, classifying their accounts as U.S. accounts, non-U.S. accounts, or recalcitrant accounts. All requests and responses made to the account holders pursuant to these requirements must be retained for 10 years.
For other accounts that have not been excluded based on the above requirements, the FFI must search its electronically searchable files for records of the listed indicia of U.S. status. As above, when such indicium is discovered, the FFI must request a Form W-9. If the account holder claims not to be a U.S. person, the manger must request a Form W-8BEN and/or documentary evidence and, in certain instances (e.g., a U.S. birthplace), a written explanation to cure the indicia of U.S. status that was identified. If such curative documentation is not obtained within two years after the effective date of the FFI’s agreement, the FFI must treat the account holder as recalcitrant.
For any remaining preexisting individual account that contains a balance of $500,000 or more at the end of the preceding year prior to the effective date of the FFI’s agreement, the FFI must perform a diligent review of the account files in search of the U.S. indicia outlined above. When such indicium is discovered, the FFI has two years from the effective date of its agreement to obtain the requisite curative documentation or treat the account holder as recalcitrant.
Finally, beginning in year three of its agreement, and each year subsequent, the FFI must perform the same review for any account that did not have a balance of at least $500,000 on the last day of the year prior to the year the FFI entered into its agreement yet did exceed this threshold on the last day of the preceding calendar year. When any listed U.S. indicium is discovered, the FFI must treat the account holder as recalcitrant if it cannot obtain the requisite curative documentation by the end of that year.
For the new documentation requirements for preexisting individual accounts outlined above, the FFI’s chief compliance officer (or equivalent) must certify to the IRS when the requirements have been completed. The timing of the certifications is within one and two years of the agreement’s effective date, depending on the requirement. The officer must also certify that the FFI has not taken any measures between April 8, 2011, and the effective date of the FFI Agreement to circumvent the account identification requirements (e.g., advise account holders with large account balances to split those balances among numerous accounts). In addition, it must certify that the FFI has written policies and procedures that prohibit an employee from doing the same.
Section I of Notice 2011-34 also clarifies uncertainties that arose from references in Section III of Notice 2010-60 and adopts, generally, the definitions of documentary evidence as set forth in Reg. sections 1.6049-5(c)(1), 1.1441-6(c)(4), the QI Agreement, and the relevant country Attachment for a qualified intermediary. Generally stated, documentary evidence means government issued photo identification. Documentation, on the other hand, includes documentary evidence, IRS Forms W-8 or W-9, and any other information records in written or electronic form that is collected in connection with the account.
Finally, Section I of Notice 2011-34 concludes that the treatment of an account holder as recalcitrant is not to be considered a long term substitute for the collection of identifying documents. The IRS and Treasury make clear that they will continue to consider alternative measures for such account holders, including the possible requirement that the FFI terminate the account relationship.
It is significant to note that the documentation requirements for private banking accounts and other accounts that meet the $500,000 threshold are considerably more onerous than those set forth in Notice 2010-60. Specifically, for these accounts, the FFI is now required to search all files, paper and electronic, for indicia of U.S. status (even where the account is documented as having non-U.S. status).
That said, when an FFI has individual account holders with no indicia of U.S. status and account balances clearly under the $500,000 threshold (for accounts other than private banking account), the new documentation rules for existing accounts will undoubtedly be useful.
In addition, the decision to limit a P.O. Box address as indicia of U.S. status to U.S. P.O. Boxes only demonstrates a willingness on behalf of Treasury and the IRS to make these documentation rules more workable.
That stated, as with the earlier guidance, the different account documentation requirements—such as those for preexisting entity accounts vs. preexisting individual accounts—may create unnecessary challenges that may be difficult to monitor. These different documentation mandates include: (1) account balance thresholds ($50,000 and $500,000 for individuals and no available thresholds for entities); (2) search requirements (electronic, paper and electronic files, any account information at all); and (3) timing in which the FFI must act).
With so many other FATCA requirements to address, observers note that a coordination of the documentation rules would make implementation more manageable. For example, it seems that the IRS would risk little to permit an FFI to forego the detailed documentation requirements for all preexisting accounts, regardless of ownership type, when: (1) the account does not receive U.S. source income; (2) there is no indicia of U.S. status associated with the account; and (3) the account is held by an FFI that is in a country where there is an income tax treaty (with an exchange of information agreement in place) with the United States.
II – Passthru Payments
As set forth in the legislation, an FFI must impose FATCA’s penal withholding on any passthru payment that it makes to a recalcitrant account holder (one that refuses to sign a waiver permitting an FFI to disclose account information under the statute, as well as one that does not comply with documentation requests in a timely manner under Notice 2010-60) or a nonparticipating FFI.
Pursuant to the statute, the definition of “passthru payment” includes a withholdable payment, as well as any amount attributable to a withholdable payment. This latter prong, attributable to a withholdable payment, had not previously been discussed in formal guidance and has been the topic of much debate. Numerous commentators asserted the need for a narrow construction on the grounds of both administration and notions of the proper territorial reach of a sovereign nation. Treasury and the IRS have rejected those assertions and, instead, have crafted what tax professionals have described as an extremely expansive definition and complex methodology with respect to passthru payments.
Pursuant to Notice 2011-34, the passthru payment rules differ for a “custodial” payment and “any other” payment. For this purpose, a custodial payment is a payment when a FFI acts as a custodian or otherwise as an agent for another person. When the custodial payment is made with respect to a debt or equity interest in another FFI (called an “issuer FFI”), the passthru payment is calculated as follows:
|Amount of payment that is a withholdable payment
||(The amount of the payment that is not a withholdable payment
x the passthru percentage of the issuer FFI).|
For any other payment, the passthru payment is calculated as follows:
|Amount of payment that is a withholdable payment
||(The amount of the payment that is not a withholdable payment
x the passthru payment percentage of the payor FFI).|
An FFI’s passthru payment percentage is calculated as follows:
|FFI’s U.S. assets (on each of four (4) quarterly testing dates)
The FFI’s total assets on those dates
The quarterly testing date is the last redemption of each quarter (for entities that conduct redemptions quarterly) and the last business day of the quarter (for all others).
The FFI is required to publish, within three months of the relevant testing date, its passthru percentage publicly (e.g., via a Web site or public domain). If it fails to do so, its deemed percentage will be 100%. Conversely, a nonparticipating FFI will be deemed to have a percentage of 0%.
An anti-abuse rule will prevent an FFI from altering its passthru payment percentage by selling and repurchasing U.S. assets around the quarterly testing dates. A U.S. financial institution (FI) will have a passthru payment percentage of 100%, though comments are requested regarding circumstances when it might be appropriate for U.S. FIs that are flow-through entities to calculate a passthru payment percentage for FFIs that hold interests in the U.S. FI (for purposes of the FFI’s own passthru payment calculation).
To determine an FFI’s assets for purposes of the calculations, an includible asset is generally any asset included in its balance sheet (future guidance will address the possible inclusion of non-balance sheet assets). It is important to note, however, that assets held in custody for others will not be included in the FFI’s calculation. The gross value of the assets, without deductions for associated liabilities, must be used. Grandfathered obligations (those outstanding on March 18, 2012) are not included as assets when calculating the FFI’s passthru payment calculation.
For purposes of the calculation, a U.S. asset is defined as any asset that could give rise to a passthru payment. In addition, a U.S. asset will include certain interests in other FFIs (e.g., funds or other collective investment vehicles). There, the interest in the other FFI (called “the lower tiered FFI”) is treated as a U.S. asset in an amount equal to the value of the FFI’s interest in the lower tiered FFI multiplied by the lower tiered FFI’s passthru payment percentage. It is important to note that stock in a U.S. corporation is treated as a U.S. asset, and stock in a foreign corporation that is not an FFI is treated as a foreign asset.
While, as indicated, many commentators had advocated for a narrow passthru payment definition, Treasury and the IRS clearly did not agree with their rationale. The definition in Notice 2011-34 is observed to be so broad, covering “any other payment” (an undefined term) when the payment is not a custodial payment, that it likely will pull in payments on interest rate swaps, derivative structured products (notwithstanding the fact that the underlying asset may not be related to a U.S. security), and any other payment the FFI is contractually obligated to make.
It is interesting to note that, although the definition is extremely broad, it does not include any payment relating to debt or equity interests in non-financial foreign entities (NFFEs) held through custody accounts. Presumably, this is because, given the account identification exceptions in the statute and Notice 2010-60 (for publicly traded NFFEs and NFFE that are in an active trade or business), the U.S. government does not seem to believe that U.S. persons committing tax fraud are doing so through direct investments in publicly traded foreign corporations or those that are engaged in an active trade or business. Perplexing, though, is the fact that the same result occurs when the investment is a debt or equity interest in a foreign fund that is a nonparticipating FFI.
As indicated above, the passthru payment percentage for a nonparticipating FFI is 0%. Thus, a U.S. person can also hold an interest in a foreign fund that did not enter into an FFI Agreement and continue to escape disclosure as well as FATCA’s penal withholding. Ironically, one of the reasons that prompted the FATCA legislation was the lack of reporting on U.S. persons investing in foreign corporations and collective investment vehicles through offshore accounts.
Notwithstanding the definition’s scope, given the complex ratios and requirements outlined above, it has been observed that the likelihood of an FFI imposing withholding on the correct amount of the payment seems remote. Specifically, the above outlined system requires every participating and deemed complaint FFI around the world to calculate and publicly post its passthru payment percentage quarterly. Even under the assumption that this occurs (recall commentators have estimated that there will be anywhere between 200,000 and 700,000 of these entities), it isn’t practicable for an FFI making such a payment to a recalcitrant account holder to search the various FFIs’ Web sites for the relevant percentage when making such a payment. This would involve time-consuming manual input into a nearly 100% automated payment system.
One thought is that the methodology is purposefully onerous, encouraging the FFI that has account holders that are recalcitrant or nonparticipating FFIs either simply to withhold on all payments or to close that account. When the definition of recalcitrant account holder is limited to an identified U.S. person who refuses to sign a waiver permitting the FFI to report, this might make sense. However, as in the statute and Notice 2010-60, the definition also includes account holders that have not timely satisfied certain documentation requests. Consequently, the FFI will also be required to treat accounts that are known to be non-U.S. as recalcitrant while awaiting documentation.
III – Deemed Complaint FFIs
Section III of Notice 20111-34 expands upon the concept of a deemed compliant FFI as described in Notice 2010-60.
- First, Notice 2011-34 makes clear that the IRS expects an FFI that is deemed compliant to apply for such status, obtain an FFI-EIN, and make a certification every third year that it continues to satisfy the relevant requirements to maintain such status.
- Second, Notice 2011-34 describes specific entities that may be deemed compliant FFIs. These entities include certain local banks, local FFI members of participating FFI groups, certain investment vehicles, and those grouped into an “other” category.
For the first classification—certain local banks—the bank will be deemed compliant when each member in its expanded affiliated group is a traditional bank (e.g., licensed, under the laws in its country of organization, as a bank or similar organization authorized to accept deposits in the ordinary course of its business); all members in the expanded affiliated group are organized in the same country; no member of the expanded affiliated group has operations outside that country or solicits account holders from outside the jurisdiction; and each member of the group adopts policies and procedures to prevent them from holding accounts for nonresidents, nonparticipating FFI account, or NFFEs (other than those that are engaged in an active trade or business in the country where the account is maintained).
For the local FFI members of participating FFI groups, Notice 2011-34 provides that a member of an expanded affiliated group that includes a participating FFI may be deemed compliant when it has no operations outside its country of organization; it does not solicit customers from outside that country; and the FFI follows the preexisting account and account identification rules for any account that is a U.S. account, nonparticipating FFI account, or NFFE account (unless the NFFE is engaged in an active trade or business in the country where the account is maintained). Further, to the extent such an account is discovered, the FFI agrees it will enter into an FFI agreement, transfer the account to a participating FFI in its group, or close the account. Thus, the local exception applies only when the member entity has a very limited account base (e.g., individuals and participating FFIs).
While observers have welcomed the expansion of the deemed compliant FFI category, they note the restrictions placed on the above entities appear far too restrictive to actually be workable without significant modifications to the FFI’s current business operations. For example, it would be very rare to have all members of an expanded affiliated group be licensed as a traditional financial institution, authorized to accept deposits, all organized in the same country, holding only accounts for residents of that country.
With respect to investment vehicles, Section III provides that such a vehicle will be deemed compliant when all direct investors are participating FFIs, deemed compliant FFIs, or exempted entities (e.g., foreign governments, central banks of issue, and those classified as such by the IRS and Treasury due to a low risk of tax evasion), the fund prohibits anyone other than those listed from acquiring an interest, and the fund certifies that it will satisfy its requirements to calculate its passthru payment percentage (outlined above).
Interestingly, though the statute excludes from the definition of financial account a debt or equity interest in a fund which is regularly traded on an established securities market (e.g., exchange traded funds), Notice 2011-34 makes clear that such entities would nevertheless have to enter into an FFI Agreement and comply with certain obligations (namely, the requirement to impose withholding on passthru payments and to calculate its passthru payment percentage), to the extent they receive a passthru payment. Notice 2011-34 indicates that Treasury and the IRS continue to contemplate deemed compliant FFI status for these types of funds. Treasury and the IRS also continue to contemplate whether funds that restrict their ownership (e.g., from specified U.S. persons) may also be deemed complaint.
With respect to funds, Notice 2011-34 acknowledges that many funds utilize transfer and paying agents when making distributions. Notice 2011-34 makes clear that the fund may use these agents to determine compliance with their FFI Agreements—although the FFI will remain liable for any compliance shortfalls. Finally, Treasury and the IRS confirm that they continue to review retirement plans that are to be deemed compliant due to the low risk of possible tax evasion by U.S. persons.
IV. Reporting on U.S. Accounts
Pursuant to the statute and Notice 2010-60, the reporting on U.S. accounts includes the account holder’s name, address, taxpayer identification number (TIN), highest month-end account balance, as well as gross receipts and withdrawals from the account.
Departing slightly from the stated reporting requirements in Notice 2010-60, Notice 2011-34 provides that reporting must include the name, address, TIN,
year-end account balances, gross income (interest, dividends, and other income) paid or credited to the account, as well as gross proceeds from the sale or redemption of property paid or credited to the account (when the FFI acted as a custodian, broker, or nominee for the account). For FFIs that are not U.S. payors, tax basis information is specifically
For U.S. accounts of FFIs that are funds or other collective investment vehicles, the FFI will be required to report the gross amount of all distributions, interest, and similar amounts credited to the account during the year, as well as each redemption payment made during the year.
If a U.S. account is closed or transferred, the FFI will be required to report the income paid or credited to the account during the year, up to the closure or transfer. It will also be required to report the amount transferred or withdrawn at the end of the account relationship. The fact that the account was closed or transferred must also be reported. Any statements issued to the account holder in the ordinary course of business must be retained for five years and provided to the IRS, upon request.
With respect to reporting of U.S. accounts held by branches of the FFI, Notice 2011-34 provides that the branch may report separately, if elected as part of the application process. When this election is not made, the FFI must identify the branch that maintains the U.S. account as part of its reporting obligations.
By limiting the account balance information to year-end balances, FFIs are more likely to be able to comply with the FATCA reporting obligations without the need to incur costly systems modifications. The question remains, however, whether the required information is excessive. It seems reasonable that the information required currently on a Form 1099 (i.e., name, address, TIN, and income paid) is sufficient for the IRS to confirm whether the specified U.S. person or substantial U.S. owner of a foreign entity has appropriately reporting the income from the account on its U.S. tax return.
V. Requirements for Qualified Intermediaries (QIs)
Notice 2011-34 makes clear that a qualified intermediary (QI) must agree to become a participating FFI (unless the QI satisfies the requirements of a deemed compliant FFI) and that the QI agreement will be updated accordingly. To assist QIs with these changes, transition rules are anticipated for the QI requirements under both chapters 3 and 4. The same requirements will apply to withholding foreign partnerships and withholding foreign trusts.
VI. Expanded Affiliates Groups
The expanded affiliated group concept has been a major concern for many potentially affected FFIs. Under the statute, the rules relating to account identification and reporting apply to FFI members of an expanded affiliated group with a participating FFI—notwithstanding the fact that the member FFI may not have ties to the U.S. (e.g., it does not receive U.S. source income). The requirements stated in Notice 2011-34 are not likely to alleviate those concerns.
Specifically, Notice 2011-34 provides that, unless the IRS agrees to permit a nonparticipating FFI in the group (this is currently under consideration), each FFI affiliate in such a group must enter into an agreement with the IRS to become a participating FFI or satisfy the requirements of a deemed compliant FFI. Each entity will be assigned its own FFI-EIN and will be solely responsible for compliance with the terms of the agreement. Of significance, the agreements will apply to each entity’s worldwide branches and offices.
To ease the execution of these agreements, Notice 2011-34 provides that each such affiliated group will appoint a lead FFI, who will complete the applications and execute the agreements for all entities in the group. Treasury and the IRS also intend to allow affiliated groups to appoint a single member as the “Compliance FFI.” As such, this Compliance FFI will be responsible for drafting policies and procedures relating to chapter 4 compliance, for determining that the policies and procedures are adopted and implemented throughout the group, and for accounting to the IRS.
Finally, for FFIs that are funds or other collective investment vehicles, the IRS is reviewing the possibility for a single asset manager or agent to assume the FATCA compliance requirements on behalf of the funds it manages. A fund manager that executes this type of single agreement would be the point of contact for all funds identified in the agreement. Liability for compliance, however, would remain with the individual funds.
The comprehensive requirements for FFI members of an expanded affiliated group are likely to be very disappointing for potentially affected entities. Many commentators had pointed out that the participating FFI in the group would not have legal authority over other group members. As a result, these commentators have advocated that it would be unfair to impute any failure by such an entity to the participating FFIs in the group that were compliant. The commentators had hoped these assertions would result in Treasury and the IRS lessening the requirements under this rule. Instead, however, the government addressed this concern by making each entity in the group solely responsible for its own FFI agreement and compliance therewith. Observers have noted that, while the streamlined process for executing the group’s agreements is likely to make tracking the entities easier for both the IRS and the group, it is unlikely to do much to negate the frustration these requirements are likely to cause.
Further, while the execution of a single agreement for hundreds of funds would significantly ease the burden for the government at the time of agreement execution, the long-term administrative requirements may not be as streamlined. Funds routinely change their managers and agents. Consequently, there will be a continuous need to update and modify existing agreements. It is believed that these constant changes are likely to cause communication problems, resulting from incorrect point persons listed on IRS databases, for the funds.
VII – Effective Date of FII Agreements
Notice 2011-34 provides that the FFI Agreement will be effective on the later of the date the agreement is executed or the effective date of section 501 of the
Hiring Incentives to Restore Employment Act (or, January 1, 2013).
Finally, it is significant to note that, like Notice 2010-60, Notice 2011-34 contains numerous specific requests for comments. Thus, these rules continue to remain very fluid and subject to change. Consequently, potentially affected entities are limited in what they are currently able to do in terms of preparation. While tax professionals may hope that Treasury and the IRS will recognize these limitations and adopt either a phased-in approach or some type of initial transitional relief, until this is done, potentially affected entities remain in a situation under which they must do what they can to prepare for the January 1, 2013 effective date.
For more information about Notice 2011-34 and related issues, contact a tax professional with KPMG’s FATCA team:
Laurie Hatten-Boyd, (206) 913 4489, email@example.com
Carl Cooper, (202) 533 6081 firstname.lastname@example.org
Steve Friedman, (202) 533 4110, email@example.com
Mark Naretti, (212) 872 7896, firstname.lastname@example.org
Melinda Schmidt, (724) 238 1212, email@example.com
Jennifer Sponzilli, (212) 872 6660, firstname.lastname@example.org
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The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.
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