Rev. Proc. 2022-43Agreement • December 12th, 2022
Contract Type FiledDecember 12th, 2022intermediary (QI) withholding agreement (QI agreement) entered into under §1.1441- 1(e)(5) that applies beginning January 1, 2023 (the 2023 QI Agreement). In general, the QI agreement allows certain 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 and allows certain persons to act as qualified derivatives dealers (QDDs) and assume primary withholding and reporting responsibilities on all dividend equivalent payments they make. The 2023 QI Agreement also allows foreign persons to enter into the agreement for purposes of the withholding and reporting required under sections 1446(a) and (f) with respect to their account holders holding interests in publicly traded partnerships.