The Internal Revenue Service (IRS) released today important guidance on its website for entities that are classified as foreign financial institutions (FFI) under the provisions of the Foreign Account Tax Compliance Act (FATCA) and considering applying for qualified intermediary (QI), withholding foreign partnership (WP), or withholding foreign trust (WT) status. The guidance is summarized below:
- In order to ensure that QI, WP or WT status is obtained prior to the July 15, 2013 FATCA registration start date, FFIs submitting an initial application for QI, WP or WT status must submit their application and all required attachments to the IRS no later than May 3, 2013.
- FATCA Portal registration will be available only for QIs, WPs or WTs that are renewing their status. This will include FFIs that obtain their initial QI, WP, or WT status in 2013.
- FFIs can submit a QI, WP, or WT application for 2013 at any time prior to November 15, 2013. Applications received by the IRS by this date will be processed to permit an FFI to register through the FATCA Portal with its QI, WP, or WT status prior to December 31, 2013.
All QI, WP, and WT agreements currently in effect will expire as of December 31, 2013. The IRS will release a revised QI, WP, and WT agreement incorporating participating FFI requirements no later than July 15, 2013.