On February 27, 2019, LB&I issued a memorandum (LB&I-04-02019-002) outlining a new program administred by the Foreign Payments Practice (“FPP”) that allows withholding agents to report and correct failures under Chapter 3 or 4.  The program and its procedures arose based upon the frequency with which taxpayers contact FPP regarding potential corrections for Chapter 3 … Continue Reading