On 7 November 2019, the U.S. Internal Revenue Service (“IRS”) released Issue Number 2019-9, which is the final reminder on the deadline for all Qualified Intermediary (“QI”), including Qualified Derivatives Dealer (“QDD”), Withholding Foreign Partnership (“WP”) and Withholding Foreign Trust (“WT”) applications for the year 2019 (Link). The deadline is 15 November 2019.
All applicants wishing to have an agreement in effect in 2019 must submit their applications through the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application & Account Management System (QAAMS) no later than 15 November 2019, to allow sufficient time for processing by year-end. Applicants must have obtained a GIIN prior to submitting their applications, if needed. See section 2.22 of the QI Agreement in Rev. Proc. 2017-15, or section 12.01(a) of the WP or WT Agreement in Rev. Proc. 2017-21 for the effective date of an agreement for a new applicant.
In addition, on 6 November 2019, Publication 3112, which is the IRS E-file Application and Participation Guidance, was updated (Link).