SECTION 1. PURPOSE

.01 In General. This Revenue Procedure sets forth the final qualified intermediary (QI) withholding agreement (QI agreement) entered into under §1.1441– 1(e)(5). ⁴ In general, the QI agreement allows foreign persons to enter into an agreement with the Internal Revenue Service (IRS) to simplify their obligations as withholding agents under chapters 3 and 4 and as payors under chapter 61 and section 3406 for amounts paid to their account holders. The QI agreement also allows certain foreign persons to enter into an agreement with the IRS to act as qualified derivatives dealers (QDDs) and to assume primary withholding and reporting responsibilities on all dividend equivalent payments that they make.

.02 Withholding Foreign Partnership and Withholding Foreign Trust Agreements. Revenue Procedure 2014-47, 2014-35 I.R.B. 393, includes the withholding foreign partnership (WP) and withholding foreign trust (WT) agreements that are currently in effect, and that are supposed to expire on December 31, 2016. This revenue procedure announces that because the updated WP and WT agreements will not be published before December 31, 2016, WPs and WTs with agreements currently in effect may continue to treat those agreements as in effect until updated agreements are issued in January 2017.