The Qualified Intermediary (“QI”) regime became effective in 2001 and related obligations, such as documentation, withholding, and reporting were part of the usual daily business of banks during the past years. In order to coordinate the obligations under FATCA (“Foreign Account Tax Compliance Act”) with those of the QI regime, a new QI agreement had been published in June 2014, which expired on 31 December 2016.
The US Internal Revenue Service (“IRS”) therefore published on 30 December 2016, as part of the Revenue Procedure 2017-15, the final revised QI Agreement that is applicable as from 1 January 2017 and detailing the requirements a bank needs to fulfill as a QI.
A bank qualifying as QI needs to properly identify, withhold upon and report all its relevant account holders for QI purposes and should certify to the IRS as from next year that it maintains effective internal controls on those aspects.
Are you familiar with the withholding and reporting principles and requirements of the new QI Agreement? PwC’s Academy offers a training providing a detailed insight into the reporting principles and requirements of the QI regime.
At the end of the training, participants will be able to:
- Explain different withholding responsibility: Primary NRA withholding, Secondary NRA withholding, and Backup withholding
- Know how to identify a payee
- Understand which income is subject to Chapter 3 and/or Chapter 4 Withholding
- Assess the correct withholding tax rate to be applied and understand how to correct situation of under- or over-withholding
- Identify the tax return and information reporting obligations of the QI
- Understand and use appropriately Forms 1042-S
- Fill out Form 1042
- Explanation of the Chapter 3 and Chapter 4 withholding principles
- How to identify a Payee for QI purposes
- Identification of a payment subject to withholding
- Application of presumption rules in absence of valid documentation
- How to proceed in case of under- or over-withholding
- Form 1042-S reporting
- Reporting pools and recipient specific reporting
- Form 1042 reporting
Our lead expert
This training is coordinated by Kerstin Thinnes, Tax Partner in charge of QI and automatic exchange of information related tax consulting, PwC Luxembourg. The team of trainers consists of experienced PwC specialists who are specialized in QI/CRS/FATCA related issues.
||Kerstin Thinnes is intensively dealing with CRS, FATCA as well as QI from the very first beginning, Kerstin has gained far reaching technical as well as practical expertise in this respect.|
She is heavily involved in projects assisting financial services clients to understand and implement these regimes.
Kerstin is an active member of QI/FATCA/CRS working groups of Luxembourg professional organizations and supports similar initiatives internationally.
This training is aimed to persons (from all impacted business lines) having already a basic understanding of the QI regime, who wish to gain more detailed knowledge about the Chapter 3 and Chapter 4 withholding.
This training is also available in German and French
Number of participants: limited to 20 participants, to ensure a high interactivity during the training
Duration: 3 hours