On 8 March 2019, the U.S. Internal Revenue Service (“IRS”) released a reminder on the due date for submission to form a Consolidated Compliance Group (“CCG”) (Link). The Qualified Intermediaries (“QI”), Withholding Foreign Partnerships (“WP”) and Withholding Foreign Trusts (“WT”) application and account management system is now accepting applications to form CCGs for certifications due in 2019. Applications should be submitted no later than 1 April 2019.
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. This 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.
Please note that the CCG should 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 should verify that their account login credentials are up to date and should consult Publication 5262 (Link), 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. QI/WP/WT entities should refer to the Certifications and Periodic Reviews FAQs to be alerted to all upcoming FAQs and to ensure those entities are compliant with that guidance (Link).
Please ensure that all filings (including Forms 1042, 1042-S, 945, 1099, and 8966), and related payments are up-to-date.