The IRS rings in the New Year with the issuance of the final Qualified Intermediary Withholding Agreement (“QI Agreement”)
Tel: +44 (0) 203 865 0626
4 January 2017
The Internal Revenue Service (“IRS”) has issued Revenue Procedure 2017-15 establishing the final Qualified Intermediary Agreement to simplify non-U.S. withholding agents’ compliance obligations under the U.S. Internal Revenue Code (“IRC”), including FATCA. Moreover, the 2017 QI Agreement allows for certain persons to also act as Qualified Derivatives Dealers (“QDDs”) and assume primary withholding and reporting responsibilities for all dividend equivalent payments made.
Further, the IRS announced that because the updated Withholding Foreign Partnership (“WP”) and Withholding Foreign Trust (“WT”) Agreements were not published prior to 31 December 2016, WPs and WTs with agreements currently in effect may continue to treat those agreements as in effect until updated agreements are issued in January 2017.
Additional information on the 2017 QI Agreement can be found at https://www.irs.gov/pub/irs-drop/rp-17-15.pdf . Hansuke will provide a more detailed review of Rev. Proc. 2017-15 in a forthcoming alert.
This publication has been written in general terms and therefore cannot be relied on to cover specific situations; application of the principles set out will depend upon the particular circumstances involved and we recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Hansuke Consulting Limited would be pleased to advise readers on how to apply the principles set out in this publication to their specific circumstances. Hansuke Consulting Limited accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication.