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Qualified Intermediary Agreement SECTION 1. PURPOSE

Qualified Intermediary Agreement Revenue Procedure 2017-15 SECTION 1. PURPOSE .01 In General. This Revenue Procedure sets forth the final Qualified Intermediary (QI) withholding Agreement (QI Agreement ) entered into under (e)(5).1 In general, the QI Agreement allows foreign persons to enter into an Agreement with the Internal Revenue Service (IRS) to simplify their obligations as withholding agents under chapters 3 and 4 and as payors under chapter 61 and SECTION 3406 for amounts paid to their account holders. The QI Agreement also allows certain foreign persons to enter into an Agreement with the IRS to act as Qualified derivatives dealers (QDDs) and to assume primary withholding and reporting responsibilities on all dividend equivalent payments that they make.

accounts. A QI that is a reporting Model 1 FFI or a registered deemed-compliant Model 1 IGA FFI will satisfy its requirement to withhold under section 1471(a) on withholdable payments made to accounts held by entities by withholding on accounts that the FFI is required to treat as held by nonparticipating FFIs.

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Transcription of Qualified Intermediary Agreement SECTION 1. PURPOSE

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