It’s that time again! The deadline for qualified intermediaries (QI), withholding foreign partnerships (WP) and withholding foreign trusts (WT) to submit applications to form a consolidated compliance group (CCG) for certifications due in 2019 is April 1, 2019. Don’t miss this opportunity to streamline your QI/WP/WT’s compliance process! Those that share similar policies, procedures, and processes for satisfying the documentation, reporting and withholding requirements of their QI/WP/WT agreement may benefit from forming a CCG, which reduces costs and administrative burdens associated with performing required periodic reviews for each entity. To apply, visit the IRS’ QI, WP, WT Application and Account Management System.
Note that for certifications due in 2019, the 2017 or 2018 tax year must be selected as the periodic review year or the IRS will reject the application. Also, those applying for a waiver of the required periodic review cannot apply to form a CCG as all members of a CCG are precluded from waiving their review.
What happens next?
Before starting the CCG application, companies should log into the system to verify that their credentials are up to date and should confirm that all required returns (including Forms 1042, 1042-S, 945, 1099, and 8966) have been filed and that related payments are current. Once the CCG application has been submitted, the IRS will confirm the composition of the group, review the sample design proposed, and notify the QI/WP/WT of any additional information needed for approval.
For more information, refer to IRS Publication 5262 and the Certifications and Periodic Reviews FAQs. Also, to learn more about RSM’s QI Periodic Review and Consulting Services, please refer to our FATCA page.