Qualified Intermediary (QI)

FATCA

FATCA: Definition of qualified intermediary [§1.1441-1(e)(5)(ii)]

[Reserved]. For further guidance, see §1.1441-1T(e)(5)(ii).

With respect to a payment to a foreign person, the term qualified intermediary means a person that is a party to a withholding agreement with the IRS and such person is –

(ii)(A) [Reserved]. For further guidance, see §1.1441-1T(e)(5)(ii)(A) [§1.1441-1(e)(5)(ii)(A)]

A foreign financial institution that is a participating FFI (including a reporting Model 2 FFI), a registered deemed-compliant FFI (including a reporting Model 1 FFI), an FFI treated as a deemed-compliant FFI under an applicable IGA that is subject to due diligence and reporting requirements with respect to its U.S. accounts similar to those applicable to a registered deemed-compliant FFI under §1.1471-5(f)(1), excluding a U.S. branch of any of the foregoing entities, or any other category of FFI identified in a qualified intermediary agreement as eligible to act as a qualified intermediary;

(ii)(B) [Reserved]. For further guidance, see §1.1441-1T(e)(5)(ii)(B) [§1.1441-1(e)(5)(ii)(B)]

A foreign branch or office of a U.S. financial institution or a foreign branch or office of a U.S. clearing organization that is either a reporting Model 1 FFI or agrees to the reporting requirements applicable to a participating FFI with respect to its U.S. accounts;

(ii)(C) [Reserved]. For further guidance, see §1.1441-1T(e)(5)(ii)(C) [§1.1441-1(e)(5)(ii)(C)]

A foreign corporation for purposes of presenting claims of benefits under an income tax treaty on behalf of its shareholders to the extent permitted to act as a qualified intermediary by the IRS; or
(ii)(D) [Reserved]. For further guidance, see §1.1441-1T(e)(5)(ii)(D) [§1.1441-1(e)(5)(ii)(D)]
Any other person acceptable to the IRS.

 

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