The QI agreement permits a foreign intermediary to simplify its obligations as a withholding agent under Chapter 3 (non-US resident withholding) and 4 (FATCA withholding), and as a payor under Chapter 61 and IRC Section 3406, for amounts paid to its account holders. The 2023 QI Agreement adopts many of the proposed changes in Notice 2022-23 (see Tax Alert 2022-0754). The QI agreement established under Revenue Procedure 2017-15 (2017 QI agreement) will expire on December 31, 2022. In Revenue Procedure 2022-43, issued On December 13, 2022, the IRS sets forth a final, revised qualified intermediary (QI) agreement (hereafter, the 2023 QI Agreement) that will apply for QI agreements entering into effect on or after January 1, 2023.
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