After approximately 18 months of taxpayer anticipation, the US Internal Revenue Service (“IRS”) has released Notice 2022-23 (which has been unofficially referred to as the “QI rider”), which proposes changes to the Qualified Intermediary (“QI”) Agreement that will permit a QI to assume withholding and reporting responsibilities for purposes of Sections 1446(a) and (f). This Legal Update provides background, notes important related dates and highlights some of the proposed updates to the QI Agreement.
