US Withholding Tax

Practical Implications of QI and FATCA

  • Ross McGill

Part of the Global Financial Markets book series (GFM)

Table of contents

  1. Front Matter
    Pages i-xxx
  2. The QI Regulations

    1. Front Matter
      Pages 1-1
    2. Ross McGill
      Pages 3-22
    3. Ross McGill
      Pages 39-62
    4. Ross McGill
      Pages 63-77
    5. Ross McGill
      Pages 79-99
    6. Ross McGill
      Pages 101-117
    7. Ross McGill
      Pages 119-125
    8. Ross McGill
      Pages 127-144
    9. Ross McGill
      Pages 145-154
  3. FATCA

    1. Front Matter
      Pages 155-155
    2. Ross McGill
      Pages 157-163
    3. Ross McGill
      Pages 165-182
    4. Ross McGill
      Pages 183-197
    5. Ross McGill
      Pages 199-216
    6. Ross McGill
      Pages 217-222
    7. Ross McGill
      Pages 223-229
  4. Related Global Tax Initiatives

    1. Front Matter
      Pages 231-231
    2. Ross McGill
      Pages 233-257
    3. Ross McGill
      Pages 259-272
    4. Ross McGill
      Pages 273-405
  5. Back Matter
    Pages 407-412

About this book


The US QI and FATCA regulations came into being in 2001 and 2010 respectively. They remain today the most challenging cross border tax regulations for financial institutions to comply with and operationalise. There is an increasing trend for financial institutions to become QIs while at the same time, the rules of the QI program become more complex and onerous. Equally, most NQIs have little idea that they are subject to these extra-territorial regulations. The US FATCA anti-tax evasion framework has also evolved through the development of intergovernmental agreements. These are complex and bilaterally jurisdiction specific as well as of multiple types. Most firms are struggling to understand the concepts and how FATCA rules overlap and are affected by QI rules. The original book on this subject by the author continues to be the only book able to explain these regulations in ways that allow financial institutions to understand their compliance obligations and take practical steps to meet them, by hearing about best practice.

This second edition builds on the basic framework of the QI and FATCA frameworks by updating the text to encompass the changes that have occurred since the book’s original publication. This edition will also delete material that has become obsolete or was proposed by the IRS originally but never implemented.


capital compliance European Union (EU) Tax Treaties QI Regulations FATCA Global Tax Initiatives QI Agreement Qualified Derivatives Dealer Status Tax withholding Understand FATCA Comply with FATCA How to account for tax withholding FATCA

Authors and affiliations

  • Ross McGill
    • 1
  1. 1.TConsult LtdYateleyUK

Bibliographic information

  • DOI
  • Copyright Information The Editor(s) (if applicable) and The Author(s), under exclusive license to Springer Nature Switzerland AG 2019
  • Publisher Name Palgrave Macmillan, Cham
  • eBook Packages Economics and Finance
  • Print ISBN 978-3-030-23084-5
  • Online ISBN 978-3-030-23085-2
  • Buy this book on publisher's site
Industry Sectors
Finance, Business & Banking