The Qualified Intermediary (QI) Program administers agreements between foreign entities, or foreign branches of certain U.S. entities, and the IRS regarding tax withholding and reporting requirements for certain U.S. source income.

The agreements administered are the Qualified Intermediary agreement and the Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) agreements. These agreements outline an entity’s withholding and reporting obligations under Chapter 3 and Chapter 4 (the Foreign Account Tax Compliance Act, commonly known as FATCA) of the Internal Revenue Code with respect to certain U.S.-source income paid to the entity’s account holders, partners and beneficiaries or owners.

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Qualified Intermediary agreement

The 2023 QI agreement PDF:

  • Simplifies entities’ obligations as withholding agents under chapter 3 (non-U.S. resident withholding) and chapter 4 (FATCA withholding) of the Internal Revenue Code (IRC) and as payors for amounts paid to their account holders under chapter 61 and section 3406 of the IRC.
  • Allows certain persons to act as qualified derivatives dealers (QDDs) to avoid withholding on certain U.S. source payments received by generally assuming primary withholding and reporting responsibilities on all dividend equivalent payments they make in a principal capacity and certain other responsibilities.
  • Allows certain persons to enter into a QI agreement for the withholding and reporting required under sections 1446(a) and (f) for account holders holding interests in publicly traded partnerships.

WP and WT agreements

The WP and WT agreements PDF generally allow certain foreign partnerships or foreign trusts to assume primary withholding and reporting obligations under chapters 3 and 4 of the IRC for certain payments of U.S. source income (such as interest, dividends, and royalties) that are distributed to, or included in the distributive shares of, their direct partners, beneficiaries, or owners, and, in some cases, persons holding interests in the partnerships or trusts indirectly through one or more foreign intermediaries or flow-through entities.

Apply, renew, certify or terminate status as a QI, WP or WT

You can apply, renew, certify or terminate status as a QI, WP or WT with the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application and Accounts Management System (QAAMS).

To enter into a QI, WP or WT agreement, applicants must establish to the satisfaction of the IRS that the entity has the resources, policies and procedures in place to comply with the terms of relevant agreement.

Use QAAMS

QI list

The QI list is maintained and updated quarterly by the Qualified Intermediary Program. It includes entities that have approved QI status and were issued QI-EINs 2 months or more before the first week of the quarter.

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