QI & FATCA News

The IRS has issued an automatic extension of the due date to submit the QI periodic certification for QIs that have a certification period ending on December 31, 2020 (e.g., certification period covering 2018 – 2020).

For QIs that intend to perform the periodic review of 2018 or 2019, or intend to request a waiver of the periodic review the extended deadline to submit the QI periodic certification is December 1, 2021.

For QIs that will perform a periodic review of the 2020 tax year, the extended deadline is March 1, 2022.

The IRS has published a revised Form W-8BEN and instructions, October 2021 version. 

Changes to the form include:

  • Check-box to indicate if a foreign TIN is not leagally required;
  • Certification regarding withholding on proceeds from the sale of an interest in a U.S. partnership under IRC §1446(f); and
  • Check-box to certify authority to sign in case form is not signed by the beneficial owner.

pdf FORM W-8BEN (10-21) (66 KB)

pdf INST W-8BEN (10-21) (190 KB)

2021 QI Deadlines

  • February 1: Form 1099 (client copy)
  • February 15: Form 1099-B (client copy)
  • March 15: Form 1042-S (client/counterparty copy)
  • March 15: Form 1042-S (IRS, electronically) – deadline extension to April 14 by timely filing Form 8809
  • March 15: Form 1042 (IRS, paper) – deadline extension to September 15 by timely filing Form 7004
  • March 31: Form 1099 (IRS, electronically) – deadline extension to April 30 by timely filing Form 8809
  • July 1: Periodic Certification, including a Periodic Review or waiver, for QIs that have a certification period ending on December 31, 2020 (e.g., 2018 to 2020)

Our Services

The QI Solutions group assists financial institutions with FATCA, QI and CRS compliance. Our services include:

  • External QI reviewer, assistance for internal QI reviewers, assistance with QI Review sample plan and requesting a waiver of the QI Review;
  • Assistance with compiling and submitting RO certifications for QI and FATCA;
  • Assistance with QI Reporting and electronic filing of Forms 1042-S and 1099 to the IRS via the IRS FIRE platform; and
  • Bespoke FATCA, QI and CRS training programs.

2020 QI Deadlines

  • January 31: Form 1099 (client copy)
  • February 15: Form 1099-B (client copy)
  • March 16: Form 1042-S (client/counterparty copy)
  • March 16: Form 1042-S (IRS, electronically) – deadline extension to April 15 by timely filing Form 8809
  • March 16: Form 1042 (IRS, paper) – deadline extension to September 15 by timely filing Form 7004
  • March 31: Form 1099 (IRS, electronically) – deadline extension to April 30 by timely filing Form 8809
  • July 1: Periodic Certification, including a Periodic Review or waiver, for QIs that have a certification period ending on December 31, 2019 (e.g., 2017 to 2019)

Our Services

The QI Solutions group assists financial institutions with FATCA, QI and CRS compliance. Our services include:

  • External QI reviewer, assistance for internal QI reviewers, assistance with QI Review sample plan and requesting a waiver of the QI Review;
  • Assistance with compiling and submitting RO certifications for QI and FATCA;
  • Assistance with QI Reporting and electronic filing of Forms 1042-S and 1099 to the IRS via the IRS FIRE platform; and
  • Bespoke FATCA, QI and CRS training programs.