Today the IRS issued Notice 2016-42 (Notice 2016-42), which sets forth the proposed qualified intermediary (QI) withholding agreement (QI agreement) entered into under Treas. Reg. § 1.1441-1(e)(5). The QI agreement published in Rev. Proc. 2014-39 expires on December 31. The revised QI agreement updates the current agreement by providing more detailed procedures regarding how qualified intermediaries satisfy their compliance review obligations and sets out terms and requirements for qualified intermediaries that want to act as qualified derivatives dealers with respect to transactions subject to section 871(m). The proposed QI agreement, when finalized, would be effective beginning January 1, 2017.
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IRS Releases Proposed Changes to QI Agreement
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