On 11 February 2020, the U.S. Internal Revenue Service (“IRS”) released issue number 2020 – 01 on the Due Date for Selection of Certification Periodic Review Year on Qualified Intermediaries (“QI”), Withholding Foreign Partnerships (“WP”) and Withholding Foreign Trusts (“WT”) Application and Account Management System (Link) with the following update:
“All QI/WP/WT entities with a certification due date of 1 July 2020, which includes entities with an effective date later than 1 January 2016 and earlier than 2 January 2017, must select the periodic review year of their certification period by 1 July 2020. This includes those entities selecting 2019 as their periodic review year. This announcement does not apply to termination certifications.
If a QI/WP/WT entity is applying for a waiver of the periodic review when making its periodic certification, it must select 2017 for its periodic review year, complete Parts I, II, and III of the certification and submit its waiver application by 1 July 2020. However, the entity will not be required to perform a periodic review if its waiver application is approved.
The IRS will notify the entity when a request for a waiver of the periodic review is approved or denied. If such request is denied with less than six months remaining before the certification due date, including any extensions, the entity will be granted a six month extension from the date of denial of the waiver to complete the periodic review and resubmit the certification. At that time, if the entity wants to select a year other than 2017 as its periodic review year, the entity should contact the FI Team at firstname.lastname@example.org. The resubmitted certification should include a completed Part IV and Part VI (if applicable).
QI/WP/WT entities should consult Publication 5262, Qualified Intermediary, Withholding Foreign Partnership, and Withholding Foreign Trust Application & Account Management User Guide (Link) before beginning their certification on the system to verify that their account login credentials are up-to-date and for login assistance, if needed. QI/WP/WT entities should also consult the IRS FAQs for Qualified Intermediaries, Withholding Foreign Partnerships, and Withholding Foreign Trusts under the heading Certifications and Periodic Reviews (Link).