Qualified Intermediary Agreement

Section 1.02 of the 2014-39 Revenue Procedure provides that a Central BANK issuing an IQ agreement can reach an agreement. A central bank issuing it is not obliged to register on the registration portal, in order to obtain participating FFI or FFI status (as described in sections 1.02 and 3.02 of Revenue Procedure 2014-39), apply for or renew the IQ agreement by filing an application or renewal application with the Foreign Media Program under 3.01 of Procedure Revenue 2014-39. An exit central bank, described in the sentence above, which renews its IQ agreement on July 31, 2014 or before July 31, 2014, will have a qi agreement effective June 30, 2014. If this IQ continues after July 31, 2014, the effective date of the IQ agreement is the renewal date indicated in the IRS Authorization Notification. A central bank issuing that is not required to obtain participating FFI status or registered FFI status and which claims IQ status has entered into an IQ agreement with the date on which it issued an IQ-EIN. Section 1.03 of the 2014-39 Revenue Procedure provides for: an IQ that submits an IQ status application before July 31, 2014, 2014 and is authorized in calendar year 2014 to act as an IQ IQ in accordance with the 2000-12 income procedure (as amended) until June 30, 2014, as if the IQ agreement for this IQ was effective on January 1, 2014 and will expire on June 30, 2014. The IRS allows a company that applications for IQ status at any time during calendar year 2014, if such an application is approved by the IRS before the end of 2014, to act as an IQ agreement from January 1, 2014 to June 30, 2014, as if the IQ agreement were in effect during that period. Therefore, an IQ is not required to apply until July 31, 2014 to qualify for this retroactive premium (as described in Section 1.03 of the 2014-39 revenue procedure). In its letter of approval to an IQ, the IRS will outline how this IQ can inform the IRS that it will act as an IQ for the full 2014 calendar year. See also IRS Qualified Intermediaries News, Issue Number 2014-03, which is completed and amended by this edition. These requirements also require the YP Act to comply with the rules on the control of foreign account payments (FATCA), although the national tax authorities have primary control over FATCA. Similar requirements apply to the retention of foreign partnerships and trusts that have equivalent agreements with the IRS.

All existing IQs must renew their qi agreements through the qi/WP/WT Application and Account Management System Portal portal by March 31, 2017 for their agreements to take effect on January 1, 2017. This portal will also be used by first-time applicants as QIs, including authorized entities applying for QDD and existing QIs that apply as QDD. A link to a system user manual (Publication 5262) effectively serves as a guide on IRS Form 14345, requesting qualified intermediaries, retaining foreign partnerships or retaining Foreign Trust status.