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Under a Qualified Intermediary Agreement with the IRS, a QI commits to the following obligations:
With the introduction of FATCA ("Foreign Account Tax Compliance Act"), new requirements were imposed on financial institutions. In order to coordinate the obligations under FATCA with those of the QI regime, a revised QI Agreement was published in June 2014 (Revenue procedure 2014-39). This revised QI Agreement changed the QI’s obligations regarding documentation, withholding, reporting and internal compliance program, and expired on 31 December 2016. Meanwhile, the US tax authorities (Internal Revenue Service - "IRS") have published Revenue Procedure 2017-15, with a new text of the QI Agreement effective on 1 January 2017.
Front-office (relationship managers collecting the documentation), back-office (processing reporting or withholding, settlement) and compliance functions are impacted. New policies and procedures as well as system enhancements need to be implemented.
PwC can assist you with the following services, covering all impacts and impacted business functions.
Pierre Kirsch
Tax Partner and Authorised Manager of the PSF, PwC Regulated Solutions S.à r.l.
Tel: +352 62133 40 31
Frauke Anna Maria Ortmann
Tax Director, PwC Regulated Solutions S.à r.l.
Tel: +352 62133 37 62