International Bank Tax Newsletter Volume 6, August 2014

International Bank Tax Newsletter Volume 6

In this issue, we provide the latest updates from the IRS, Treasury department, and much more.

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IRS Releases Updated Qualified Intermediary (QI) Agreement

On June 27, 2014, the Internal Revenue Service (IRS) released Revenue Procedure 2014-39, containing an updated and final QI Agreement to replace the prior version set forth in Revenue Procedure 2000-12. Many of the modifications to the new Agreement relate to harmonizing a QI’s requirements under chapters 3 and 61 of the Code to its chapter 4, Foreign Account Tax Compliance Act (FATCA), requirements. Notwithstanding certain fundamental modifications to the prior QI Agreement, the IRS did not issue the new agreement in draft form.

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