Intermediary
Definition: An intermediary is a custodian, broker, nominee, middleman,or any other person that acts as an agent for another person. A non-US (foreign) intermediary is… Read More »Intermediary
Definition: An intermediary is a custodian, broker, nominee, middleman,or any other person that acts as an agent for another person. A non-US (foreign) intermediary is… Read More »Intermediary
Definition: A Grantor Trust is a trust that has a grantor who retains interest or control of the trust. The grantor is subject to anti-abuse… Read More »Grantor Trust
Definition: A nonwithholding foreign simple trust is any foreign simple trust that is not a withholding foreign trust. A nonwithholding foreign grantor trust is any… Read More »Nonwithholding Foreign Trust
Definition: A nonwithholding foreign partnership is any foreign partnership other than a withholding foreign partnership. See Page 6
Definition: A nonqualified intermediary (NQI) is any intermediary that is a non-US (foreign) person and that is not a qualified intermediary. This means that the NQI has not… Read More »Nonqualified Intermediary
Definition A Foreign Simple or Grantor Trust is considered non-US (foreign) unless it meets both the following tests. – A court within the United States… Read More »Foreign Simple or Grantor Trust
Definition A Qualified Intermediary (QI) Agreement is an agreement between the QI and the Internal Revenue Service (IRS) in order to simplify the obligations of… Read More »Qualified Intermediary Agreement
Definition: A qualified intermediary (QI) is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified intermediary withholding agreement with the… Read More »Qualified Intermediary
Definition: A QDD is a qualified intermediary that is an eligible entity that agrees to meet the requirements of Regulations section 1.1441-1(e)(6)(i) and the QI… Read More »Qualified Derivatives Dealers
Definition A Complex Trust is not a Simple Trust and is able to accumulate income, distribute amounts other than current income, and make payments for charitable purposes.… Read More »Complex Trust