New Year’s Gifts: IRS Issues Final 2023 QI Agreement and Additional Code Sec. 1446(f) Guidance

In December 2022, the U.S. Internal Revenue Service (“IRS”) issued Rev. Proc. 2022-43, which provides the final qualified intermediary (“QI”) agreement.1 The prior QI agreement2 (the “2017 QI Agreement”) expired at the end of 2022. The new QI agreement (the “2023 QI Agreement”) came into effect on January 1, 2023, and is set to expire on December 31, 2028.