The IRS posted FAQ’s today on the effective dates of FATCA agreements for entities that apply on or after April 1 to be withholding foreign partnerships or withholding foreign trusts.
Qualified Intermediaries: Withholding Foreign Partnerships/ Withholding Foreign Trusts
Q1. How does a Financial Institution that is not currently a Qualified Intermediary (“QI”), a Withholding Foreign Partnership (“WP”), or a Withholding Foreign Trust (“WT”) register to become one?
Q2. How do FIs that are currently QIs, WPs and WTs renew their agreements?
Q3. I am not currently a QI/WP/WT. Can I use the LB&I registration portal to register for FATCA and become a new QI/WP/WT?
Q4. Must an FI become a QI/WP/WT in order to register under FATCA?
Q5. If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer?
Q6. If a member of the Expanded Affiliated Group is a Qualified Intermediary/Withholding Trust/Withholding Partnership, does the Lead Financial Institution renew the Qualified Intermediary/Withholding Trust/Withholding Partnership agreement on behalf of the member or does the member renew its own agreement?
Q7. How will Withholding Foreign Partnerships (WP) and Withholding Foreign Trusts (WT) renew their WP and WT agreements, if the revised WP and WT agreements will not be published before June 30, 2014?
Q8. When will the terms of the revised QI Agreement set forth in Revenue Procedure 2014-39 be effective for: (a) entities seeking QI status, and (b) entities seeking renewal of their QI Agreements?
Q9. If an entity submits an application for WP or WT status on or after April 1 and is approved for such status, what will the effective date of its WP or WT agreement be?
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Original Post By: Ronald Marini