2017 QI Reporting – 2018 Deadlines – QI Review and RO Certification

2017 QI Reporting (for income paid in 2017)

As in past years, all of the IRS forms for QI reporting, including requesting an extension, are available on our web site. Remember that Form 1042-S and Form 1099 must be filed electronically.

New Form 8809 (09-2017) and IRS Address for Submission

Form 8809 is used to request an automatic 30 day extension of time to file Form 1042-S (and Form 1099). The new address for paper submission of Form 8809 is:

  • Ogden - IRS Submission Processing Center
  • 1973 Rulon White Blvd.
  • Ogden, UT 84201
  • U.S.A.

Changes to Form 1042-S: Unique Form Identifier and Amended Forms

Form 1042-S now includes a box for a Unique Form Identifier ("UFI"), which must be a unique 10 digit number. Each time a Form 1042-S is amended it will retain its UFI and the amended box will be used to indicate a sequential amendment number, beginning with "1".

Form 1099 Reporting

A QI must perform Form 1099 reporting for US clients that have received US source income. In certain cases the QI’s Form 1099 reporting obligation can be satisfied if the client’s account is subject to FATCA reporting (including FATCA reporting to the local tax authorities in a Model 1 IGA country). Note, however, that Form 1099 reporting must be performed in case the client’s account is not a financial account for FATCA purposes (e.g., pensions or other Annex II products) or in case the payments to the US client have been subject to US withholding (which generally results when the client is in an omnibus account together with non-US clients).

Deadlines for 2018 QI Fulfillments

  • January 31: Form 8966 (only for Swiss FFIs with financial accounts held by non-consenting US account holders)
  • January 31: 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 16 by timely filing Form 8809
  • March 15: Form 1042 (IRS, paper) – deadline extension to September 17 by timely filing Form 7004
  • April 2: Form 1099 (IRS, electronically) – deadline extension to April 30 by timely filing Form 8809
  • April 2: Form 8966 (IRS, electronically) – deadline extension to June 29 by timely filing Form 8809-I

QI Review and RO Certification

In 2018 most QIs will be required to perform the initial certification of sufficiency of internal controls ("Periodic Certification") and perform the Periodic Review by an internal or external reviewer. In certain circumstances QIs may request a waiver of the Periodic Review. The initial Certification Period covers the first three calendar years in which the QI had a QI agreement in effect since July 1, 2014, which in most cases will be the years 2015, 2016 and 2017. A QI may choose any year in the Certification Period for the RO certifications.

The deadline to submit the RO certification of compliance with the IRS is December 31, 2018 in case the third year of the Certification Period is chosen, and July 1, 2018 in case the first or second year is chosen or in case the QI requests a waiver of the Periodic Review. We expect further guidance from the IRS regarding the manner in which the certification will be submitted, however we anticipate that this will carried out on the IRS QI Management website.

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.