In recent Notice 2016-42, the IRS has proposed a new qualified intermediary (QI) agreement. The current QI agreement, set forth in Rev. Proc. 2014-39 (“the 2014 QI agreement”), expires December 31, 2016. The IRS expects to...more
On October 29, the Internal Revenue Service (IRS) issued Notice 2013-69, which includes guidance to foreign financial institutions (FFIs) entering into FFI agreements with the IRS and a draft FFI agreement. The Notice also...more