Qualified Intermediary or Bust?

4 Pages Posted: 10 Aug 2009

See all articles by Susan C. Morse

Susan C. Morse

University of Texas at Austin - School of Law

Date Written: August 3, 2009


In reaction to news about wealthy U.S. individuals hiding assets in non-U.S. bank accounts, the Obama administration has proposed statutes that would make non-qualified intermediary (NQI) status more unattractive for non-U.S. banks. The proposals appear to push non-U.S. banks into qualified intermediary (QI) agreements with the IRS, and under accompanying proposals QIs would undertake expanded responsibilities to automatically provide information about U.S. clients to the IRS. But models other than the QI system could also serve the enforcement goal of international automatic information exchange. Fortunately, the proposals also would permit Treasury and the IRS to craft administrative exceptions to adverse NQI rules. Officials could use this discretion to support the development of effective automatic information exchange agreements and systems whether or not they followed the QI template.

Keywords: qualified intermediary, international information exchange, residence taxation

JEL Classification: H20, H24, K34

Suggested Citation

Morse, Susan C., Qualified Intermediary or Bust? (August 3, 2009). Tax Notes, Vol. 124, No. 5, 2009, Santa Clara Univ. Legal Studies Research Paper No. 2009, Available at SSRN: https://ssrn.com/abstract=1444291

Susan C. Morse (Contact Author)

University of Texas at Austin - School of Law ( email )

727 East Dean Keeton Street
Austin, TX 78705
United States

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