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The Treasury Department and IRS intend to issue rules that will say that a debt obligation will be considered to be in registered form if it is issued through a dematerialized book entry system maintained by a clearing organization or clearing system in which the obligation is effectively immobilized, IRS says in Notice 2012-20. In addition, IRS provides a limited transition rule in which a withholding agent paying interest on an obligation issued in registered form after March 18, 2012, and before Jan. 1, 2014, may apply the foreign targeted registered obligation rules if the obligation satisfied the requirements of those rules.
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