The IRS announced that it has extended the deadline for Qualified Intermediary (QI), Withholding Foreign Partnership (WP), and Withholding Foreign Trust (WT) periodic review certifications due in 2024, providing additional time to complete periodic reviews or waiver applications.

The IRS QI/WP/WT Application and Accounts Management System (QAAMS) portal has also been updated to extend renewals of WP/WT Agreements to March 31, 2025.

Certification process

Periodic certifications are submitted through the IRS QAAMS portal by the QI's/WP's/WT's Responsible Officer (RO) for each "certification period." The initial certification period is the period ending on the third full calendar year that the applicable agreement is effective.

The due date for the certifications depends on (1) which of the three years in the certification period is used for the periodic review, and (2) whether a waiver of the periodic review requirement is obtained. For a QI/WP/WT that uses the third year of the certification period, the certification is generally due on or before December 31 of the year following the certification period. For example, an QI/WP/WT certification would be due December 31, 2023, if the certification period were January 1, 2020, through December 31, 2022, and the QI/WP/WT choose 2022 as the periodic review year.

The IRS extended the due dates for certification periods ending December 21, 2023 (i.e., certifications due in 2024) as follows:

• For entities selecting periodic review years 2021 or 2022 or submitting a waiver application, the due date is extended from July 1, 2024 to September 1, 2024
• For entities selecting periodic review year 2023, the due date is extended from December 31, 2024 to March 1, 2025

The extensions are automatic and do not require action by entities with a certification due date in 2024. The link to the 2024 Certifications in QAAMS will be available later in 2024.

The IRS did not address whether QIs/WP/WTs must log into the QAAMS portal to select the periodic review year of their certification before July 1 or September 1. As in prior years, this may be confirmed later through updated FAQs on the IRS website.

EY observes

The QAAMs portal and homepages previously reflected a WP/WT Agreement renewal date of December 31, 2023, with the IRS asking taxpayers to complete renewals after the December 31 expiration date. The updated QAAMS portal now reflects a March 31, 2025 Agreement renewal date. The IRS previously discouraged WPs or WTs from submitting renewals early, which caused some QAAMS portal-certification-submission problems for those with a certification due in 2023.

WPs or WTs with a certification due in 2024 (with extension to 2025) should consider waiting until the certifications have been submitted before renewing the WP Agreement so that approval of the renewal does not interfere with submission of the certification.