QI & FATCA News
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The IRS has published Form W-8IMY, June 2017 version. The revised form includes certifications for Qualified Derivative Dealers, and modifies the certifications for sponsored FFIs to reflect the requirement for these FFIs to have their own GIIN. In addition, the certifications regarding primary withholding and reporting responsibility for QIs in part III (line 15) have been simplified.
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The IRS has opened the Qualified Intermediary, Withholding Foreign Partnership, and Withholding Foreign Trust Application & Account Management System ("QI Portal"). The QI Portal will be used to apply for or terminate QI status as well as renew the QI agreement. To view the IRS QI Portal click here.
The IRS has also published a user guide, contained in Publication 5262, to assist QIs regarding the QI Portal.
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On January 4, 2017 the IRS published Revenue Procedure 2017-15 (the "2017 QI agreement") that contains the new QI agreement and incorporates many of the proposals from Notice 2016-42. The 2017 QI agreement introduces major changes to the QI agreement contained in Revenue Procedure 2014-39 and will require QIs to implement procedures regarding, among others, the QI compliance program and treaty documentation for entity clients. Below are highlights of the main issues that QIs will need to consider.
Read more: New QI Agreement Published: Revenue Procedure 2017-15
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The IRS has published a new Form W-8BEN (version January 2017) to certify non-US status of individuals.
