U.S. Tax Reporting and Withholding  
  Qualified Intermediary ("QI") Advice  
  Tax Advice and Planning  
  Cross-Border Financial Structures  
  Collective Investment Vehicles ("CIVs")  
  Audit and Appellate Controversies  
  Tax Litigation  
  Rulings and Regulatory Lobbying  
  Alternative Dispute Resolution  
  Expert Witness/Litigation Support Services  
  Advice for Governments  

Qualified Intermediary (“QI”) Advice

QIs must comply with both local and U.S. tax reporting and withholding rules. We have worked closely with QIs and QI auditing firms advise them on how these rules work.

As Associate Chief Counsel (International) for the IRS, John Staples, now our Washington managing partner, and Phil Garlett worked for half a decade with numerous banking associations in Europe and Asia to refine the QI program. Their intimate knowledge of the rules and our excellent working relationships with the IRS allow us to provide superior service to QIs, including:

  • Helping them negotiate QI agreements and renewals with the IRS.
  • Negotiating rulings and other agreements with the IRS regarding the application of the QI regime.
  • Advising QIs how to properly set up their withholding and reporting systems.
  • Issuing opinions on the proper application of QI agreements, income tax treaties, and other withholding and reporting rules.
  • Advising QIs when to invoke, and when not to invoke, their QI status.
  • Providing second opinions when QIs properly question the positions taken by their outside auditors.
  • Resolving disputes with the IRS.


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