December 15, 2022
IRS publishes 2023 QI agreement, allowing foreign persons to participate
In Revenue Ruling 2022-43, the IRS sets forth the final qualified intermediary (QI) withhold agreement entered into under Treas. Reg. Section 1.1441-1(e)(5) that applies beginning January 1, 2023 (the 2023 QI agreement). While the QI agreement generally allows certain persons to enter into agreement with the IRS to simplify their withholding-agent obligations (among other things), the 2023 QI Agreement also allows foreign persons to enter into the agreement for purposes of the withholding and reporting required under IRC Sections 1446(a) and (f) for their account holders with interests in publicly traded partnerships.
Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor