On November 6, the IRS issued its final reminder alert that the deadline for all Qualified Intermediary (“QI”) (including Qualified Derivatives Dealer (“QDD”)), Withholding Foreign Partnership (“WP”) and Withholding Foreign Trust (“WT”) applications for the 2019 year is November 15, 2019.
In general, a QI agreement allows a foreign intermediary to simplify its obligations as a withholding agent under chapters 3 and 4 and as a payor under chapter 61 and section 3406 for amounts paid to its account holders. Similarly, a WP or WT agreement allows a foreign partnership or foreign trust to assume the withholding and reporting obligations under chapters 3 and 4 for certain payments of U.S.-source income (such as interest, dividends, and royalties) made to its partners, beneficiaries, or owners.
Applicants seeking to have an agreement in effect for 2019 must submit an application through the IRS’s online system. Note that applicants will typically need to obtain a Global Intermediary Identification Number (“GIIN”) prior to submitting an application. For more information about QI agreements, see Revenue Procedure 2017-15. For more information about WP and WT agreements, see Revenue Procedure 2017-21.