Tax regulations require that PTPs send DTC qualified notices as a registered holder that is also a nominee. PTPs should send Qualified Notices to [email protected]. When DTC first announces a distribution from a PTP the distribution is coded with IRS Income Code 58 “publicly traded partnership distributions – undetermined.” When DTC receives the Qualified Notice from the PTP, the Announcement is updated to:
- Reflect the IRS Income Code(s) as detailed on the Qualified Notice, and
- If the Qualified Notice states that all, a portion, or none of the distribution is in Excess of CNI, then a 1446(f) Excess of Cumulative Net Income Announcement is created providing the amount of the distribution that is in excess of CNI.
Independent of the distribution, Qualified Notices may also provide for an exception to withholding requirements on a transfer and brokers may rely on the qualified notice for 92 days from the posting date. When DTC receives as Qualified Notice providing such an exception, a 92 Day Exemption Qualified Notice Announcement is created providing the Posting Date as provided on the Qualified Notice.