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> Information provided on this site is for general guidance only and is often simplified. Actual IRS procedures are complex, and taxpayers should obtain professional assistance or use IRS sources for complete information.


Introduction: What The Legislation Does
The legislation setting up Qualified Intermediary status is contained in the IRS Tax Code in Section 1.1441-1 through 9.

The Legislation
The text file of Section 1.1441 occupies 650KB.

Approved Countries With 'Attachments'
Links to the QI agreements between the IRS and country 'attachments'.
Supplementary IRS documentation
QI and Withholding Agent FAQs


Annex I: The Legislation

The text file of Section 1.1441 occupies 650KB.

The following paragraph from the opening of the text describes the purpose of the various sections. Click on the section header to link to the full text for that section.

Section 1.1441-1 Requirement for the deduction and withholding of tax on payments to foreign persons.

(a) Purpose and scope. This section, Secs. 1.1441-2 through 1.1441- 9, and 1.1443-1 provide rules for withholding under sections 1441, 1442, and 1443 when a payment is made to a foreign person.

This section provides definitions of terms used in chapter 3 of the Internal Revenue Code (Code) and regulations thereunder. It prescribes procedures to determine whether an amount must be withheld under chapter 3 of the Code and documentation that a withholding agent may rely upon to determine the status of a payee or a beneficial owner as a U.S. person or as a foreign person and other relevant characteristics of the payee that may affect a withholding agent's obligation to withhold under chapter 3 of the Code and the regulations thereunder. Special procedures regarding payments to foreign persons that act as intermediaries are also provided.

Section 1.1441-2 defines the income subject to withholding under section 1441, 1442, and 1443 and the regulations under these sections.

Section 1.1441-3 provides rules regarding the amount subject to withholding.

Section 1.1441-4 provides exemptions from withholding for, among other things, certain income effectively connected with the conduct of a trade or business in the United States, including certain compensation for the personal services of an individual.

Section 1.1441-5 provides rules for withholding on payments made to flow-through entities and other similar arrangements.

Section 1.1441-6 provides rules for claiming a reduced rate of withholding under an income tax treaty.

Section 1.1441-7 defines the term withholding agent and provides due diligence rules governing a withholding agent's obligation to withhold.

Section 1.1441-8 provides rules for relying on claims of exemption from withholding for payments to a foreign government, an international organization, a foreign central bank of issue, or the Bank for International Settlements.

Sections 1.1441-9 and 1.1443-1 provide rules for relying on claims of exemption from withholding for payments to foreign tax exempt organizations and foreign private foundations.

BACK TO TOP

Introduction: What The Legislation Does
The legislation setting up Qualified Intermediary status is contained in the IRS Tax Code in Section 1.1441-1 through 9.

The Legislation
The text file of Section 1.1441 occupies 650KB.

Approved Countries With 'Attachments'
Links to the QI agreements between the IRS and country 'attachments'.
Supplementary IRS documentation
QI and Withholding Agent FAQs

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