RP-2014-39: Application Procedures and Overview of Requirements for Qualified Intermediary Status Under Chapters 3, 4, and 61 and Section 3406

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IRS GuideWire June 27, 2014

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Issue Number:    RP-2014-39

Inside This Issue


Revenue Procedure 2014-39 updates the Qualified Intermediary (QI) agreement published in Rev. Proc. 2000-12, 2000-1 C.B. 387 (as amended) applicable to foreign intermediaries that wish to enter into a QI withholding agreement with the IRS under §1.1441-1(e)(5).  The QI agreement is being updated to reflect the enactment of Chapter 4 (§§1471-1474) of the Code, and the issuance of regulations under section 3406 and chapters 3, 4, and 61 of the Code.   Rev. Proc. 2014-39 supersedes Rev. Prov. 2000-12 with respect to the requirements of a QI that apply on or after June 30, 2014, and is effective as of the date of public release.

Revenue Procedure 2014-39 will be published in IRB 2014-29, dated July 14, 2014.

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