On July 23, the IRS issued a bulletin calling on the company to extend or obtain a qi agreement until July 31, 2014. This follows the 2014-39 VAT procedure, which included the new IQ agreement. If you have provided the IRS with the necessary information as part of your FATCA registration to renew an IQ agreement, no further action should be required. If you have not yet provided this information, we advise you that it be completed by July 31 to ensure that your IQ agreement is extended. We provided an update below on the key changes that result from the new IQ agreement. The new IQ agreement will expire on December 31, 2016 and will be aligned with the FFI agreement. An IQ that submits an IQ application before July 31, 2014 and was approved in the course of 2014 may, from January 1, 2014 to June 30, 2014, apply in accordance with the agreement. 2000-12. 2. Specific changes highlighted in the new IQ agreement An FFI that has entered into an IQ agreement is subject to fatca requirements for all accounts it manages, whether or not it is an account designated by qi. The Ministry of Finance and the IRS were very busy at the end of 2016 and began in 2017 with a bang: (1) announced Jan. 17 the introduction of a new intermediation system (IQ), Withholding Foreign Partnership (WP) and Withholding Trust (WT) Application and Account Management System (Announcement), (2) publication of a new agreement on foreign financial institutions (see Rev. Proc.
2017-16) and a final agreement on IQ (see Rev. Proc. 2017-15) December 30, 2016 and (3) publication, January 6, 2017, four sets of temporary provisions (TD 9808, TD 9809) and proposed provisions (REG 103477-14, REG 134247-16) regulating reporting and withholding in chapters 3, 4 and 61 of the Revenue Code. The agreements and regulations followed the publication of a new Foreign Account Compliance Compliance Act (FATCA) Online Registration Guide (FATCA), published in December 2016. The documentation requirements under the new IQ agreement are similar to those previously, so that an IQ (i.e. an FFI) can continue to use documentary leads (as an alternative to W-8 forms) that are authorized by IRS-authorized customer rules, which are authorized by the IRS. These requirements do not apply to an IQ that is an NFFE required to obtain the W-8 and W-9 forms of its account holders. The PFFIs, which had to renew their contracts before 31 December 2016, now have until 31 July 2017 to renew their contracts. A participating FFI that does not renew its agreement until this extended period is treated as if it had terminated its FFI agreement as of January 1, 2017.
Any agreement in effect before June 30, 2014 expired that day.