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ARTICLE · 12 MAY 2023

New Year's Gifts: IRS Issues Final 2023 QI Agreement And Additional Code Sec. 1446(f) Guidance

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In December 2022, the U.S. Internal Revenue Service ("IRS") issued Rev. Proc. 2022-43, which provides the final qualified intermediary ("QI") agreement...

United StatesTax
Bruna Barbosa
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Jared Goldberger
Jared Goldberger
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In December 2022, the U.S. Internal Revenue Service ("IRS") issued Rev. Proc. 2022-43, which provides the final qualified intermediary ("QI") agreement.1 The prior QI agreement2 (the "2017 QI Agreement") expired at the end of 2022. The new QI agreement (the "2023 QI Agreement") came into effect on January 1, 2023, and is set to expire on December 31, 2028.

The 2023 QI Agreement includes significant updates compared to the 2017 QI Agreement. First, and most notably, the 2023 QI Agreement largely adopts the changes proposed by the IRS in 2022 in Notice 2022-23 (commonly referred to as the "QI Rider"), which included proposed modifications relating to a QI's ability to act in such capacity with respect to receiving certain amounts from interests in publicly traded partnerships ("PTPs")3 and the QI's withholding obligations under Code Secs. 1446(a) and 1446(f) of the Internal Revenue Code (the "Code"). In addition, the 2023 QI Agreement incorporates prior IRS

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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