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By Marie-Sophie DERVIEU, Partner, Tax Eva CONSTANTIN, Senior Manager, Tax, EY Luxembourg
Published on 13 December 2022, the 2023 Qualified Intermediary (QI) Agreement, known as the Rev. Proc. 2022-43, was entered into by the Internal Revenue Service (IRS) and eligible entities as per the corresponding regulations, including foreign financial institutions, foreign clearing organizations, and foreign branches of U.S. financial institutions and clearing organizations.
It took effect on 1 January 2023 and brings significant changes for financial institutions acting as QIs. With a short implementation period, these institutions must act quickly to assess the impact of the new agreement on their operations, including changes to documentation,...
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