Archive | Qualified Intermediary

IRS Voluntary Disclosure – Foreign Tax Havens

In the 1990s, foreign tax havens greatly increased offshore tax evasions for U.S. taxpayers by use of undisclosed bank accounts, offshore credit/debit cards and money laundering. According to Senator Carl Levin” “Offshore tax evasion produces an estimated $100 billion in unpaid taxes each year. It’s long past time to collect these taxes and stop the […]

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Non-Qualified Intermediary – NQI

February 27, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

Payors of U.S. source income to a NQI can treat the payment as reasonably associated with valid documentation from a specific payee, if prior to making the payment; 1. The payor can allocate the payment to a valid Form W8 IMY; 2. The payor can determine how much of the payment relates to valid documentation […]

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Qualified Intermediary – QI General

February 26, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

A QI is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified withholding agreement with the IRS. A QI is a payee (of U.S. source income) to the extent the QI assumes primary withholding responsibility as primary Form 1099 reporting and backup withholding responsibility for a payment, in […]

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Qualified Intermediary – Withholding Rules

February 26, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

A qualified intermediary (“QI”) is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified withholding agreement with the IRS: 1. For NRA tax withholding, unlike payments to foreign intermediaries, where the payees are the persons to whom the foreign intermediary collects the payments (e.g. account holders), the QI […]

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