As reported in our previous information, the IRS extended the time to renew the QI Agreement until May 1, 2023, since for the majority of QIs the link to the renewal application was not available in the QI Application and Account Management System (QAAMS).
We would like to inform that as of February 13, 2023, the link is available in the QAAMS and the QI Agreement can now be renewed by everyone.
To renew the QI Agreement, QIs are required to log in to their account in the QAAMS and click the link “Renew Agreement” in the Activity Center at the bottom of the Home Page. Most fields in the renewal application are pre-filled with information entered during the original registration.
While completing the renewal application, we recommend carefully reviewing the pre-filled information and update it if required. If there were material changes to the QIs business description or account opening process, QIs are required to prepare a separate document to describe the changes and upload it as an attachment to Part 4 of the renewal request. Also, as confirmed by the IRS in the FAQ, the information regarding the type of account holders and investment in U.S. assets in Part 2 of the renewal application does not have to be updated.
Once renewed, the new QI Agreement will be considered retroactively in force from January 1, 2023 and will expire on December 31, 2028.
Swiss QIs should note that there has not yet been an official statement from the Federal Department of Finance as to whether a renewal of the permission to act as QI will be required. We are expecting that the FDF will unilaterally extend the permission to all existing QIs, as it did with the 2017 QI Agreement.