A19. Section 1.01 of the WP agreement provides that a WP that is a reverse hybrid foreign company must meet the requirements of Section 6.03 (C) of the WP agreement, which contain a requirement that the foreign hybrid be an FFI. Notwithstanding this requirement, a foreign auto-hybrid company that is an NFFE can: apply for a WP with respect to payments of income from personal services that are an income actually related to a business or business within the United States, when it also meets the requirements of an NFFE under the WP agreement (including reporting information on reluctant payments distributed to a partner or included in the distribution share of a partner that is an NFFE, as described in Section 6.05 (B) ).2) If a WP that is a foreign reverse hybrid has filed a request and has not activated the Part 1 box to indicate its status as a foreign reverse hybrid entity, it must email the FI team to correct email@example.com its status. Added: 12-08-2017 The IRS had no intention of changing the applicability of kyc facilities approved in the 2017 IQ, WP and WT agreements. Therefore, an IQ, WP or WT reference institution may consider an authorized kyc facility to be an integral part of its agreement, as long as the installation does not apply to the business (or the company branch, if any). Added: 12-19-2017 Internal Revenue Service (IRS) published December 30, 2016 Rev. Proc. 2017-15, which includes the final agreement of qualified intermediary (IQ) 2017 (IQ agreement 2017). The 2017 qi agreement provides for procedures for QIs (including qualified derivatives traders (QDDs) and eligible securities lenders (QSLs) to meet their reporting and retention obligations in the United States.
For more information, check out our Insight: IRS publishes the qualified final agreement. A qualified intermediary (IQ) is any foreign intermediary (or foreign branch of a U.S. intermediary) who has entered into a qualified withholding agreement with the IRS. You can treat an IQ as a tax-exempt beneficiary, as long as the IQ assumes the primary responsibility for the withholding and the primary responsibility for the return and guarantee reserve for a payment.