Final qualified intermediary (QI) agreement | KPMG | US
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KPMG report: Final qualified intermediary (QI) agreement

Final qualified intermediary (QI) agreement

The IRS on December 30, 2016, released an advance version of Rev. Proc. 2017-15, containing a revised final qualified intermediary (QI) agreement that replaces the current version of the QI agreement as previously set forth in Rev. Proc. 2014-39.


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The final QI agreement contains several noteworthy modifications from a proposed agreement (released on July 2, 2016). Among several significant areas of change are:

  • Updated rules relating to qualified derivatives dealers (QDDs)
  • Changes to certain documentation and due diligence rules
  • Additional guidance surrounding the compliance review
  • Certain reporting relief


Read a January 2017 report [PDF 1.4 MB] prepared by KPMG LLP that highlights and discusses modifications in the final QI agreement. The KPMG report discusses:

  • The updated QDD regime
  • Significant changes to certain due diligence rules
  • More onerous requirements relating to certain treaty claims
  • Updated information relating to compliance review, including waivers
  • Modifications to the joint account reporting and review rules

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