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
- 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
- Providing second opinions when QIs properly question the positions
taken by their outside auditors.
- Resolving disputes with the IRS.