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United States: Consolidated compliance group reminder for QIs / WPs / WTs

United States: Consolidated compliance group reminder

The IRS issued a release advising that the qualified intermediary / withholding foreign partnership / withholding foreign trust (QI/WP/WT) application and account management system is accepting applications to form consolidated compliance groups (CCGs) for certifications under the consolidated compliance program for 2019. The deadline for CCG applications is 1 April 2019.

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Upon submission of an application to form a CCG, the IRS will contact the compliance entity to request any further information necessary to determine if the CCG is acceptable to the IRS.  Any ongoing discussion will also address such issues as the final composition of the group members and sample design for any statistical sampling to be utilized for the periodic review.

The IRS release notes that the CCG must select 2017 or 2018 as the periodic review year.  The IRS will not approve CCG applications that select 2016 as the periodic review year for the certification due in 2019.

QI/WP/WT entities are directed to:

  • Verify that their account login credentials are up to date and consult Publication 5262 Qualified Intermediary, Withholding Foreign Partnership, and Withholding Foreign Trust Application & Account Management User Guide, before beginning their CCG applications on the system, and for login assistance, if needed
  • Refer to the Certifications and Periodic Reviews FAQs so as to be alerted to all upcoming FAQs and to ensure those entities are compliant with that guidance.
  • Determine that all filings (including Forms 1042, 1042-S, 945, 1099, and 8966), and related payments are up-to-date

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