QI alert - Issue 2018-01
On 22 February 2018, the Internal Revenue Service (IRS) announced that beginning in early April the QI/WP/WT application and account management system will begin accepting Responsible Officer compliance certifications from qualified intermediaries (QI), withholding foreign partnerships (WP), and withholding foreign trusts (WT).
In preparation for the upcoming certification deadline, the IRS advises QI/WP/WT entities to verify that their account login credentials, filings (including Form 1042, 1042-S, 945, and 1099), and related payments are up to date.
2015 and 2016 review year
Per the QI/WP/WT agreements, 1 July 2018 is the certification due date for a QI/WP/WT that selected 2015 or 2016 for its periodic review and that has a certification period ending in 2017, or that obtained a waiver of its periodic review and that has a certification period ending in 2017.
The IRS has announced an extension of time to provide certification to 1 September 2018.
2017 review year
Per the QI/WP/WT agreements, 31 December 2018, is the certification due date for a QI/WP/WT that selected 2017 for its periodic review.
The IRS has announced an extension of time to provide certification to 1 March 2019.
Please note that the IRS has not made any announcements regarding possible due date extensions for the FATCA responsibility officer certifications. (These certifications are required for FFIs that have entered into the FFI Agreement or those operating under a Model 2 Intergovernmental Agreement).
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.