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Operational tax news - Qualified Intermediary regime update - 23 March 2011


Important QI deadlines coming up in 2011

QI audit

30 June 2011 is an important date for Qualified Intermediaries (“QIs”) that entered into a QI Agreement in 2007 and have a Years 1 & 3 “audit” cycle.

By 30 June 2011, these QIs must either:

  • Undergo a QI “audit” (in strictness, it is not an audit but an Agreed Upon Procedures engagement) and have the results submitted to the IRS
  • Apply for an ‘audit’ extension through their external auditor
  • Submit an ‘audit’ waiver request

Further information on extensions is detailed below.


On application to the IRS, “audit” extensions to 31 December 2011 or exceptionally later may be available. An “audit” extension request must be submitted by your external auditor by 30 June 2011.

In order to apply for an extension the IRS have stated that the external auditor must be engaged by the QI to perform the QI ‘audit’ review.

Please contact us should you wish to apply for an “audit” extension.


As in previous years, “audit” waivers may be available on application to the IRS for QIs with reportable amounts below $1,000,000 (waiver # 1) or between $1,000,000 and $4,000,000 (waiver # 2) if certain criteria are met.

For further information on waivers, please refer to our Operational Tax News “2010 audit waiver templates available” dated March 2011.

If you have any queries regarding the above, please do not hesitate to contact us.



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