The IRS issued a reminder to all qualified intermediaries / withholding foreign partnerships / withholding foreign trusts (QI/WP/WT) entities with a certification period ending in 31 December 2017 to log into the QI/WP/WT Application and Account Management System to select the periodic review year of their certification period by 1 September 2018. This also applies to those entities selecting 2017 as their periodic review year.
The certification due date for a QI/WP/WT that selected 2015 or 2016 for its periodic review is 1 September 2018. The certification due date for a QI/WP/WT that selected 2017 for its periodic review is 31 December 2018 (the IRS is granting an extension to 1 March 2019 to provide the certification).
The IRS transmittal message notes that if a QI/WP/WT entity is applying for a waiver of the periodic review when making its periodic certification, it must select 2015 for its periodic review year, complete Parts I, II, and III of the certification, and submit its waiver application by 1 September 2018. The entity will not be required to perform a periodic review if its waiver application is approved.
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