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US | Changes to QI withholding agreement rules expand QI withholding and reporting responsibilities

12 May 2022

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Tax Alerts, National/Federal Taxation, Information Reporting, Legislation & Policy

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United States

The United States (US) Internal Revenue Service (IRS) has published changes (Notice 2022-23) to the qualified intermediary (QI) withholding agreement rules that will allow a QI to assume withholding and reporting responsibilities for purposes of Internal Revenue Code (IRC) Sections 1446(a) and (f). Generally, these changes would apply to a QI that sells an interest in a publicly traded partnership (PTP) or receives a distribution from a PTP on behalf of a QI account holder.BackgroundQI agreementThe current QI agreement, established under Revenue Procedure 2017-15 (see EY Global Tax Alert, IRS releases 2017 Qualified Intermediary Agreement and FFI Agreement, dated 18...