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Entity Classification Election- form 8832

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Entity Classification Election- form 8832

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									Form    8832
(Rev. March 2007)                                       Entity Classification Election                                                           OMB No. 1545-1516

Department of the Treasury
Internal Revenue Service
            Name of eligible entity making election                                                                            Employer identification number


Type        Number, street, and room or suite no. If a P.O. box, see instructions.
or
Print       City or town, state, and ZIP code. If a foreign address, enter city, province or state, postal code and country. Follow the country’s practice for entering the
            postal code.



       Check if:      Address change



 1      Type of election (see instructions):

   a        Initial classification by a newly-formed entity. Skip lines 2a and 2b and go to line 3.
   b        Change in current classification. Go to line 2a.

 2a Has the eligible entity previously filed an entity election that had an effective date within the last 60 months?

            Yes. Go to line 2b.
            No. Skip line 2b and go to line 3.

 2b Was the eligible entity’s prior election for initial classification by a newly formed entity effective on the date of formation?

            Yes. Go to line 3.
            No. Stop here. You generally are not currently eligible to make the election (see instructions).

 3      Does the eligible entity have more than one owner?

             Yes. You can elect to be classified as a partnership or an association taxable as a corporation. Skip line 4 and go to line 5.
             No. You can elect to be classified as an association taxable as a corporation or disregarded as a separate entity. Go to
             line 4.
 4      If the eligible entity has only one owner, provide the following information:
   a Name of owner
   b Identifying number of owner


 5      If the eligible entity is owned by one or more affiliated corporations that file a consolidated return, provide the name and
        employer identification number of the parent corporation:
   a Name of parent corporation
   b Employer identification number

For Paperwork Reduction Act Notice, see instructions.                                      Cat. No. 22598R                                   Form   8832    (Rev. 3-2007)
Form 8832 (Rev. 3-2007)                                                                                                               Page   2
 6     Type of entity (see instructions):

   a      A   domestic eligible entity electing to be classified as an association taxable as a corporation.
   b      A   domestic eligible entity electing to be classified as a partnership.
   c      A   domestic eligible entity with a single owner electing to be disregarded as a separate entity.
   d      A   foreign eligible entity electing to be classified as an association taxable as a corporation.
   e      A   foreign eligible entity electing to be classified as a partnership.
   f      A   foreign eligible entity with a single owner electing to be disregarded as a separate entity.

  7 If the eligible entity is created or organized in a foreign jurisdiction, provide the foreign country of
    organization

  8 Election is to be effective beginning (month, day, year) (see instructions)                                               /       /

  9 Name and title of contact person whom the IRS may call for more information              10 Contact person’s telephone number

                                                                                                (       )

                                     Consent Statement and Signature(s) (see instructions)
Under penalties of perjury, I (we) declare that I (we) consent to the election of the above-named entity to be classified as indicated
above, and that I (we) have examined this consent statement, and to the best of my (our) knowledge and belief, it is true, correct,
and complete. If I am an officer, manager, or member signing for all members of the entity, I further declare that I am authorized to
execute this consent statement on their behalf.

                      Signature(s)                                 Date                                     Title




                                                                                                                    Form   8832   (Rev. 3-2007)
Form 8832 (Rev. 3-2007)                                                                                                                    Page   3

General Instructions                               Eligible entity. An eligible entity is a           will become a disregarded entity when the
                                                   business entity that is not included in            entity’s membership is reduced to one
Section references are to the Internal             items 1, or 3 through 9, under the                 member and a disregarded entity will be
Revenue Code unless otherwise noted.               definition of corporation provided under           classified as a partnership when the entity
                                                   Definitions.                                       has more than one member.
What’s New                                            Eligible entities include limited liability     Foreign default rule. Unless an election is
This revision of the Form 8832                     companies (LLCs), partnerships, and any            made on Form 8832, a foreign eligible
instructions reflects an update to the filing      foreign entity that is not identified as a         entity is:
locations. Our previous revision                   corporation under Regulations section                 1. A partnership if it has two or more
(December 2006) stated that all entity             301.7701-2(b)(8) (see item 3 below).               members and at least one member does
classification elections were sent to the             Generally, corporations are not eligible        not have limited liability.
service center in Ogden, UT. This is no            entities. However, the following types of             2. An association taxable as a
longer the case. Now the form is filed             corporations are treated as eligible               corporation if all members have limited
either in Cincinnati or Ogden depending            entities:                                          liability.
upon your principal business location.
                                                      1. An eligible entity that previously              3. Disregarded as an entity separate
See Where To File on page 4 for your
                                                   elected to be an association taxable as a          from its owner if it has a single owner
filing location.
                                                   corporation by filing Form 8832. An entity         that does not have limited liability.
● You are not required to sign the copy            that elects to be classified as a
of Form 8832 filed with your tax return.           corporation by filing Form 8832 can make           Definitions
See Consent statement and signature(s)             another election to change its
on page 6.                                                                                            Association. For purposes of this form,
                                                   classification (see the 60-month limitation
● New questions on lines 2a and 2b highlight                                                          an association is an eligible entity taxable
                                                   rule discussed below in the instructions for
the general rule which limits an eligible                                                             as a corporation by election or, for foreign
                                                   lines 2a and 2b).
entity’s ability to change its classification by                                                      eligible entities, under the default rules
                                                      2. A foreign eligible entity that became        (see Regulations section 301.7701-3).
election again during the 60 months after the      an association taxable as a corporation
effective date of making an earlier entity         under the foreign default rule described           Business entity. A business entity is any
classification election.                           below.                                             entity recognized for federal tax purposes
● All single-owner eligible entities electing         3. A foreign corporation that is not
                                                                                                      that is not properly classified as a trust
either corporate or disregarded entity status                                                         under Regulations section 301.7701-4 or
                                                   identified as a corporation under
must provide the name and identifying                                                                 otherwise subject to special treatment
                                                   Regulations section 301.7701-2(b)(8). If a
number of their owner on lines 4a and 4b.                                                             under the Code regarding the entity’s
                                                   foreign corporation is not identified on the
Previously this requirement applied only to                                                           classification. See Regulations section
                                                   list included in these regulations, it
single-owner eligible entities electing                                                               301.7701-2(a).
                                                   qualifies as an eligible entity. See the list of
disregarded entity status.                         Foreign Entities Classified as Corporations        Corporation. For federal tax purposes, a
● All eligible entities owned by one or more       for Federal Tax Purposes under this                corporation is any of the following:
affiliated corporations that file a consolidated   regulation on page 6. Refer to the                   1. A business entity organized under a
return must provide the name and employer          regulations for any changes to the list            federal or state statute, or under a statute
identification number (EIN) of their parent        made after these instructions were printed.        of a federally recognized Indian tribe, if
corporation on lines 5a and 5b. Previously            The IRS will use the information entered        the statute describes or refers to the
this requirement applied only to single-owner      on this form to establish the entity’s filing      entity as incorporated or as a corporation,
eligible entities electing disregarded entity      and reporting requirements for federal tax         body corporate, or body politic.
status.                                            purposes.
● All foreign eligible entities making an entity                                                        2. An association (as determined under
                                                                                                      Regulations section 301.7701-3).
classification election, including those also      Default Rules                                        3. A business entity organized under a
organized under domestic law, must provide
the name of the foreign country in which they      Existing entity default rule. Certain              state statute, if the statute describes or
are organized on line 7. Previously this           domestic and foreign entities that were in         refers to the entity as a joint-stock
requirement applied only to single-owner           existence before January 1, 1997, and              company or joint-stock association.
foreign eligible entities electing disregarded     have an established federal tax                      4. An insurance company.
entity status.                                     classification generally do not need to
                                                                                                        5. A state-chartered business entity
                                                   make an election to continue that
                                                                                                      conducting banking activities, if any of its
Purpose of Form                                    classification. If an existing entity decides
                                                                                                      deposits are insured under the Federal
                                                   to change its classification, it may do so
An eligible entity uses Form 8832 to elect                                                            Deposit Insurance Act, as amended, 12
                                                   subject to the 60-month limitation rule.
how it will be classified for federal tax                                                             U.S.C. 1811 et seq., or a similar federal
                                                   See the instructions for lines 2a and 2b.
purposes, as a corporation, a partnership,                                                            statute.
                                                   See Regulations sections 301.7701-3(b)(3)
or an entity disregarded as separate from          and 301.7701-3(h)(2) for more details.               6. A business entity wholly owned by a
its owner. An eligible entity is classified                                                           state or any political subdivision thereof,
for federal tax purposes under the default         Domestic default rule. Unless an                   or a business entity wholly owned by a
rules described below unless it files Form         election is made on Form 8832, a                   foreign government or any other entity
8832 or Form 2553, Election by a Small             domestic eligible entity is:                       described in Regulations section
Business Corporation, to elect a                      1. A partnership if it has two or more          1.892-2T.
classification or change its current               members.                                             7. A business entity that is taxable as a
classification. See Who Must File on                  2. Disregarded as an entity separate            corporation under a provision of the Code
page 4.                                            from its owner if it has a single owner.           other than section 7701(a)(3).
             A new eligible entity should             A change in the number of members of              8. A foreign business entity listed on
             not file Form 8832 if it will be      an eligible entity classified as an                page 6. See Regulations section
  TIP        using its default classification      association (defined below) does not               301.7701-2(b)(8) for any exceptions and
             (see Default Rules below).            affect the entity’s classification. However,       inclusions to items on this list and for any
                                                   an eligible entity classified as a partnership     revisions made to this list since these
                                                                                                      instructions were printed.
Form 8832 (Rev. 3-2007)                                                                                                                   Page   4
   9. An entity created or organized under        ● Electing to be classified as an                 ● The due date for the entity’s desired
the laws of more than one jurisdiction            S corporation. An eligible entity that timely     classification tax return (excluding
(business entities with multiple charters) if     files Form 2553 to elect classification as        extensions) for the tax year beginning with
the entity is treated as a corporation with       an S corporation and meets all other              the entity’s formation date has not passed,
respect to any one of the jurisdictions.          requirements to qualify as an S                   and
See Regulations section 301.7701-2(b)(9)          corporation is deemed to have made an             ● The entity has reasonable cause for its
for examples.                                     election under Regulations section                failure to make a timely election.
Disregarded entity. A disregarded entity          301.7701-3(c)(v) to be classified as an
is an eligible entity that is treated as an       association taxable as a corporation.                To obtain relief, a newly formed entity
entity not separate from its single owner.            All three of these entities are deemed to     must file Form 8832 on or before the due
Its separate existence will be ignored for        have made an election to be classified as         date of the first federal tax return
federal tax purposes unless it elects             an association.                                   (excluding extensions) of the entity’s
corporate tax treatment.                                                                            desired classification. The entity must also
                                                  Effect of Election                                write “FILED PURSUANT TO REV. PROC.
Limited liability. A member of a foreign                                                            2002-59” at the top of the form. The entity
eligible entity has limited liability if the      The federal tax treatment of elective             must attach a statement to the form
member has no personal liability for any          changes in classification as described in         explaining why it failed to file a timely
debts of or claims against the entity by          Regulations section 301.7701-3(g)(1) is           election. If Rev. Proc. 2002-59 does not
reason of being a member. This                    summarized as follows:                            apply, an entity may seek relief for a late
determination is based solely on the              ● If an eligible entity classified as a           entity election by requesting a private
statute or law under which the entity is          partnership elects to be classified as an         letter ruling and paying a user fee in
organized (and, if relevant, the entity’s         association, it is deemed that the                accordance with Rev. Proc. 2006-1,
organizational documents). A member has           partnership contributes all of its assets         2006-1 I.R.B. 1 (or its successor).
personal liability if the creditors of the        and liabilities to the association in
entity may seek satisfaction of all or any        exchange for stock in the association, and        Where To File
part of the debts or claims against the           immediately thereafter, the partnership           File Form 8832 with the Internal Revenue
entity from the member as such. A                 liquidates by distributing the stock of the       Service Center for your state listed below.
member has personal liability even if the         association to its partners.
member makes an agreement under which                                                                   Attach a copy of Form 8832 to the
                                                  ● If an eligible entity classified as an          entity’s federal tax return for the tax year
another person (whether or not a member           association elects to be classified as a
of the entity) assumes that liability or                                                            of the election. If the entity is not required
                                                  partnership, it is deemed that the                to file a return for that year, a copy of its
agrees to indemnify that member for that          association distributes all of its assets and
liability.                                                                                          Form 8832 must be attached to the
                                                  liabilities to its shareholders in liquidation    federal tax returns of all direct or indirect
Partnership. A partnership is a business          of the association, and immediately               owners of the entity for the tax year of
entity that has at least two members and          thereafter, the shareholders contribute all       the owner that includes the date on which
is not a corporation as defined on                of the distributed assets and liabilities to a    the election took effect. Failure to attach
page 3 under Corporation.                         newly formed partnership.                         a copy of Form 8832 will not invalidate an
                                                  ● If an eligible entity classified as an          otherwise valid election, but penalties
Who Must File                                     association elects to be disregarded as an        may be assessed against persons who
File this form for an eligible entity that is     entity separate from its owner, it is             are required to, but do not, attach Form
one of the following:                             deemed that the association distributes all       8832.
● A domestic entity electing to be                of its assets and liabilities to its single          Each member of the entity is required
classified as an association taxable as a         owner in liquidation of the association.          to file their return consistent with the
corporation.                                      ● If an eligible entity that is disregarded as    entity election. Penalties apply to returns
                                                  an entity separate from its owner elects to       filed inconsistent with the entity’s
● A domestic entity electing to change its
                                                  be classified as an association, the owner        election.
current classification (even if it is currently
classified under the default rule).               of the eligible entity is deemed to have
                                                  contributed all of the assets and liabilities
● A foreign entity that has more than one         of the entity to the association in exchange      If the entity’s principal   Use the following
owner, all owners having limited liability,                                                         business,                   Internal Revenue
                                                  for the stock of the association.
electing to be classified as a partnership.                                                         office, or agency is        Service Center
                                                  Note. For information on the federal tax          located in:                 address:
● A foreign entity that has at least one          consequences of elective changes in
owner that does not have limited liability,       classification, see Regulations section           Connecticut, Delaware,
electing to be classified as an association       301.7701-3(g).                                    District of Columbia,
taxable as a corporation.                                                                           Illinois, Indiana,
● A foreign entity with a single owner            When To File                                      Kentucky, Maine,
having limited liability, electing to be an       An election specifying an eligible entity’s       Maryland,
entity disregarded as an entity separate          classification cannot take effect more than       Massachusetts,
                                                                                                    Michigan, New           Cincinnati, OH 45999
from its owner.                                   75 days prior to the date the election is
                                                                                                    Hampshire, New Jersey,
● A foreign entity electing to change its         filed, nor can it take effect later than 12
                                                                                                    New York, North
current classification (even if it is currently   months after the date the election is filed.      Carolina, Ohio,
classified under the default rule).                  Late election relief. A newly formed           Pennsylvania, Rhode
                                                  entity may be eligible for late election relief   Island, South Carolina,
  Do not file this form for an eligible entity                                                      Vermont, Virginia, West
                                                  under Rev. Proc. 2002-59, 2002-39 I.R.B.
that is:                                                                                            Virginia, Wisconsin
                                                  615 if:
● Tax-exempt under section 501(a);
                                                  ● The entity failed to obtain its desired
● A real estate investment trust (REIT), as       classification solely because Form 8832
defined in section 856; or                        was not timely filed,
Form 8832 (Rev. 3-2007)                                                                                                                  Page   5
                                                  Note. Any entity that has an EIN will           entity wants to be classified under the
If the entity’s principal     Use the following   retain that EIN even if its federal tax         default rules.
business,                     Internal Revenue    classification changes under Regulations           Check box 1b if the entity is changing
office, or agency is          Service Center      section 301.7701-3.                             its current classification.
located in:                   address:
                                                     If a disregarded entity’s classification     Lines 2a and 2b. 60-month limitation
                                                  changes so that it becomes recognized           rule. Once an eligible entity makes an
Alabama, Alaska,
Arizona, Arkansas,
                                                  as a partnership or association for federal     election to change its classification, the
California, Colorado,                             tax purposes, and that entity had an EIN,       entity generally cannot change its
Florida, Georgia, Hawaii,                         then the entity must continue to use that       classification by election again during the
Idaho, Iowa, Kansas,                              EIN. If the entity did not already have its     60 months after the effective date of the
Louisiana, Minnesota,                             own EIN, then the entity must apply for         election. However, the IRS may (by
Mississippi, Missouri,        Ogden, UT 84201     an EIN and not use the identifying              private letter ruling) permit the entity to
Montana, Nebraska,                                number of the single owner.                     change its classification by election within
Nevada, New Mexico,                                  A foreign person that makes an election      the 60-month period if more than 50% of
North Dakota,                                                                                     the ownership interests in the entity, as of
                                                  under Regulations section 301.7701-3(c)
Oklahoma, Oregon,                                                                                 the effective date of the election, are
South Dakota,                                     and (d) must also use its own taxpayer
                                                  identifying number. See sections 6721           owned by persons that did not own any
Tennessee, Texas, Utah,
Washington, Wyoming                               through 6724 for penalties that may apply       interests in the entity on the effective date
                                                  for failure to supply taxpayer identifying      or the filing date of the entity’s prior
                                                  numbers.                                        election.
A foreign country or
                          Ogden, UT 84201-0023       If the entity electing to be classified      Note. The 60-month limitation does not
U.S. possession
                                                  using Form 8832 does not have an EIN, it        apply if the previous election was made
Note. Also attach a copy to the entity’s          must apply for one on Form SS-4,                by a newly formed eligible entity and was
federal income tax return for the tax year        Application for Employer Identification         effective on the date of formation.
of the election.                                  Number. If the filing of Form 8832 is the       Line 4. If an eligible entity has only one
                                                  only reason the entity is applying for an       owner, provide the name of its owner on
Acceptance or                                     EIN, check the “Other” box on line 9 of         line 4a and the owner’s identifying
Nonacceptance of Election                         Form SS-4 and enter “Form 8832” to the          number (social security number, or
                                                  right of that box. The entity must have         individual taxpayer identification number,
The service center will notify the eligible       received an EIN by the time Form 8832 is        or EIN) on line 4b. Enter “DE” if the owner
entity at the address listed on Form 8832         filed in order for the form to be               is a disregarded entity that does not have
if its election is accepted or not accepted.      processed. An election will not be              an identifying number. If the owner is a
The entity should generally receive a             accepted if the eligible entity does not        foreign person or entity and does not
determination on its election within 60           provide an EIN. Caution. Do not apply for       have a U.S. identifying number, enter
days after it has filed Form 8832.                a new EIN for an existing entity that is        “none” on line 4b.
    Care should be exercised to ensure            changing its classification if the entity
                                                                                                  Line 5. If the eligible entity is owned by
that the IRS receives the election. If the        already has an EIN.
                                                                                                  one or more members of an affiliated
entity is not notified of acceptance or           Address. Enter the address of the entity        group of corporations that file a
nonacceptance of its election within 60           electing a classification. All                  consolidated return, provide the name
days of the date of filing, take follow-up        correspondence regarding the                    and EIN of the parent corporation.
action by calling 1-800-829-0115, or by           acceptance or nonacceptance of the
sending a letter to the service center to                                                         Line 6. Check the appropriate box if you
                                                  election will be sent to this address.          are changing a current classification (no
inquire about its status. Send any such           Include the suite, room, or other unit
letter by certified or registered mail via                                                        matter how achieved), or are electing out
                                                  number after the street address. If the         of a default classification. Do not file this
the U.S. Postal Service, or equivalent            Post Office does not deliver mail to the
type of delivery by a designated private                                                          form if you fall within a default
                                                  street address and the entity has a P.O.        classification that is the desired
delivery service (see Notice 2004-83,             box, show the box number instead of the
2004-52 I.R.B. 1030 (or its successor)).                                                          classification for the new entity.
                                                  street address. If the electing entity
    If the IRS questions whether Form 8832        receives its mail in care of a third party      Line 7. If the entity making the election is
was filed, an acceptable proof of filing is:      (such as an accountant or an attorney),         created or organized in a foreign
 ● A certified or registered mail receipt         enter on the street address line “C/O”          jurisdiction, enter the name of the foreign
 (timely postmarked) from the U.S. Postal         followed by the third party’s name and          country in which it is organized. This
 Service, or its equivalent from a                street address or P.O. box.                     information must be provided even if the
 designated private delivery service;             Address change. If the eligible entity has      entity is also organized under domestic law.
● Form 8832 with an accepted stamp;               changed its address since filing Form           Line 8. Generally, the election will take
                                                  SS-4 or the entity’s most recently-filed        effect on the date you enter on line 8 of
● Form 8832 with a stamped IRS
                                                  return (including a change to an “in care       this form, or on the date filed if no date is
received date; or
                                                  of” address), check the box for an              entered on line 8. An election specifying
● An IRS letter stating that Form 8832
                                                  address change.                                 an entity’s classification for federal tax
has been accepted.
                                                  Note. If a change of address occurs after       purposes can take effect no more than 75
                                                  the later of the filing of Form SS-4 or the     days prior to the date the election is filed,
Specific Instructions                             most recently-filed return, use Form 8822,      nor can it take effect later than 12 months
Name. Enter the name of the eligible              Change of Address, to notify the IRS of         after the date on which the election is
entity electing to be classified.                 the new address. A new address shown            filed. If line 8 shows a date more than 75
                                                  on Form 8832 will not update the entity’s       days prior to the date on which the
Employer identification number (EIN).                                                             election is filed, the election will default to
Show the EIN of the eligible entity               address of record with the IRS.
                                                  Line 1. Check box 1a if the entity is           75 days before the date it is filed. If line 8
electing to be classified.                                                                        shows an effective date more than 12
Caution. Do not put “Applied For” on this         choosing a classification for the first time
                                                  (i.e., the entity does not want to be           months from the filing date, the election
line.                                                                                             will take effect 12 months after the date
                                                  classified under the applicable default
                                                  classification). Do not file this form if the   the election is filed.
Form 8832 (Rev. 3-2007)                                                                                           Page   6

Consent statement and signature(s).                                                Malaysia—Berhad
Form 8832 must be signed by:                   Foreign Entities Classified as      Malta—Public Limited Company
   1. Each member of the electing entity       Corporations for Federal Tax        Mexico—Sociedad Anonima
who is an owner at the time the election       Purposes:                           Morocco—Societe Anonyme
is filed; or                                   American Samoa—Corporation          Netherlands—Naamloze
   2. Any officer, manager, or member of       Argentina—Sociedad Anonima             Vennootschap
the electing entity who is authorized          Australia—Public Limited Company    New Zealand—Limited Company
(under local law or the organizational                                             Nicaragua—Compania Anonima
documents) to make the election. The
                                               Austria—Aktiengesellschaft
                                               Barbados—Limited Company            Nigeria—Public Limited Company
elector represents to having such
authorization under penalties of perjury.      Belgium—Societe Anonyme             Northern Mariana
                                               Belize—Public Limited Company       Islands—Corporation
   If an election is to be effective for any
period prior to the time it is filed, each     Bolivia—Sociedad Anonima            Norway—Allment Aksjeselskap
person who was an owner between the            Brazil—Sociedade Anonima            Pakistan—Public Limited Company
date the election is to be effective and       Canada—Corporation and Company      Panama—Sociedad Anonima
the date the election is filed, must sign.     Chile—Sociedad Anonima              Paraguay—Sociedad Anonima
   If you need a continuation sheet or use     People’s Republic of China—Gufen    Peru—Sociedad Anonima
a separate consent statement, attach it to        Youxian Gongsi                   Philippines—Stock Corporation
Form 8832. The separate consent                Republic of China (Taiwan)—Ku-fen   Poland—Spolka Akcyjna
statement must contain the same                   Yu-hsien Kung-szu                Portugal—Sociedade Anonima
information as shown on Form 8832.             Colombia—Sociedad Anonima           Puerto Rico—Corporation
Note. Do not sign the copy that is             Costa Rica—Sociedad Anonima         Romania—Societe pe Actiuni
attached to your tax return.                   Cyprus—Public Limited Company       Russia—Otkrytoye Aktsionernoy
                                               Czech Republic—Akciova                 Obshchestvo
                                                  Spolecnost                       Saudi Arabia—Sharikat
Paperwork Reduction Act                        Denmark—Aktieselskab                   Al-Mossahamah
Notice                                         Ecuador—Sociedad Anonima or         Singapore—Public Limited
We ask for the information on this form to        Compania Anonima                    Company
carry out the Internal Revenue laws of the     Egypt—Sharikat Al-Mossahamah        Slovak Republic—Akciova
United States. You are required to give us     El Salvador—Sociedad Anonima           Spolocnost
the information. We need it to ensure that     Estonia—Aktsiaselts                 Slovenia—Delniska Druzba
you are complying with these laws and to       European Economic                   South Africa—Public Limited
allow us to figure and collect the right       Area/European Union—                   Company
amount of tax.                                                                     Spain—Sociedad Anonima
                                                  Societas Europaea
   You are not required to provide the         Finland—Julkinen Osakeyhtio/        Surinam—Naamloze Vennootschap
information requested on a form that is           Publikt Aktiebolag               Sweden—Publika Aktiebolag
subject to the Paperwork Reduction Act                                             Switzerland—Aktiengesellschaft
unless the form displays a valid OMB           France—Societe Anonyme
                                               Germany—Aktiengesellschaft          Thailand—Borisat Chamkad
control number. Books or records relating
to a form or its instructions must be          Greece—Anonymos Etairia                (Mahachon)
retained as long as their contents may         Guam—Corporation                    Trinidad and Tobago—Limited
become material in the administration of       Guatemala—Sociedad Anonima             Company
any Internal Revenue law. Generally, tax       Guyana—Public Limited Company       Tunisia—Societe Anonyme
returns and return information are             Honduras—Sociedad Anonima           Turkey—Anonim Sirket
confidential, as required by section 6103.                                         Ukraine—Aktsionerne Tovaristvo
                                               Hong Kong—Public Limited
   The time needed to complete and file           Company                             Vidkritogo Tipu
this form will vary depending on individual    Hungary—Reszvenytarsasag            United Kingdom—Public Limited
circumstances. The estimated average           Iceland—Hlutafelag                     Company
time is:                                                                           United States Virgin Islands—
                                               India—Public Limited Company
Recordkeeping                1 hr., 49 min.    Indonesia—Perseroan Terbuka            Corporation
Learning about the                             Ireland—Public Limited Company      Uruguay—Sociedad Anonima
law or the form              2 hr., 7 min.     Israel—Public Limited Company       Venezuela—Sociedad Anonima or
Preparing and sending                          Italy—Societa per Azioni               Compania Anonima
the form to the IRS                23 min.     Jamaica—Public Limited Company
                                                                                              See Regulations section
  If you have comments concerning the          Japan—Kabushiki Kaisha
accuracy of these time estimates or                                                           301.7701-2(b)(8) for any
                                               Kazakstan—Ashyk Aktsionerlik
suggestions for making this form simpler,                                                     exceptions and inclusions
                                                  Kogham                            CAUTION
we would be happy to hear from you.                                                           to items on this list and
                                               Republic of Korea—Chusik Hoesa
You can write to the Internal Revenue                                              for any revisions made to this list
Service, Tax Products Coordinating             Latvia—Akciju Sabiedriba
                                                                                   since these instructions were
Committee, SE:W:CAR:MP:T:T:SP,                 Liberia—Corporation
                                                                                   printed.
1111 Constitution Ave. NW, IR-6406,            Liechtenstein—Aktiengesellschaft
Washington, DC 20224. Do not send the          Lithuania—Akcine Bendroves
form to this address. Instead, see Where       Luxembourg—Societe Anonyme
To File on page 4.

								
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