It is without doubt that the documentation process of the QI is a simplified process to that of the Non-QI. ![]() ![]() However, they have to disclose the information of their direct customers in the form of W-8, W-9 or KYC documentation plus a detailed withholding statement disclosing the details of each beneficiary to their upstream custodians or the IRS. Although a Non-QI does not have an agreement with the IRS, their responsibilities are practically the same as a QI with regard to documentation and reporting. customers without revealing their identity either to upstream custodians or to the IRS.Īn Intermediary that does not apply to become a QI will, by default, be a Non-QI. residence on behalf of its direct clients, thereby obtaining a reduced rate of U.S. These procedures are subject to verification (two times in a six year period) by an external auditor.Ī QI can certify treaty residence and/or non-U.S. The QI Agreement requires that the QI must implement certain documentary procedures to identify its clients that invest in US securities. financial institution that has entered into a QI Agreement with the IRS. Although the Qualified Intermediary (QI) regime has been around for quite some time, simple questions surrounding the terminology and structure still remain quite common. For example, what is an Intermediary, a Qualified Intermediary, and a Non-Qualified Intermediary?Īn Intermediary is any person or organisation holding securities other than for its own account.
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