Tax Regulatory Services

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Qualified Intermediary Services 

Specialist QI support across advisory, reporting, compliance, remediation and IRS interactions

Financial institutions investing in U.S. securities may need to comply with the U.S. Qualified Intermediary (QI) regime. The QI framework remains one of the most demanding tax regulatory regimes, requiring certain institutions to meet extensive documentation, withholding, reporting, governance, internal controls and certification obligations, while keeping pace with increasing digitalization and heightened expectations from the IRS.

Failures in QI processes can lead to reporting errors, withholding exposures, remediation costs, increased regulatory scrutiny and reputational damage. A robust QI framework is therefore not only a technical requirement under the QI Agreement — it is a core operational control.

BDO Luxembourg’s Tax Regulatory Services team provides practical, end-to-end QI support. We assist clients throughout the full QI lifecycle, from application or renewal of QI status to day-to-day advisory, reporting, compliance program design, periodic certifications and periodic reviews, remediation, and IRS liaison.

Our specialists combine deep U.S. tax technical knowledge with extensive financial sector experience. We help you translate QI requirements into workable processes, controls and reporting outputs.

Our QI Services

QI advisory and technical support

We provide targeted advice on complex QI questions, including documentation, withholding, reporting, account holder classification, treaty relief, intermediary structures and operational implementation.

Our support includes:

  • Assistance with QI status assessment, application or renewal
  • Ad hoc technical support for complex or time-sensitive QI issues
  • Training sessions and tailored technical workshops
  • Support with interpretation of QI Agreement requirements
  • Assistance with U.S. federal tax classification questions linked to QI operations

QI compliance program support

We help institutions design, implement, review and strengthen their QI Compliance Program.

Our support includes:

  • Implementation or review of QI Compliance Programs
  • Preparation or review of QI policies, procedures, governance frameworks and internal controls
  • Independent health checks and gap assessments with prioritized practical remediation recommendations 
  • Remediation planning and execution
  • Support to Internal Audit functions in assessing QI compliance and controls
  • QI periodic review support
  • Assistance with QI certifications and periodic review waiver requests

QI reporting services

We support the preparation, review and submission of QI reporting, including Forms 1042 and 1042-S.

Our work may include:

  • Preparation or independent quality review of QI reporting
  • Data consistency checks and reconciliation
  • E-filing support via FIRE System, MeF, IRIS, IDES
  • Review of withholding and reporting positions
  • Support with corrections and post-filing follow-up


QI outsourcing services

Where additional operational support is required, we provide flexible outsourcing solutions, including:

  • Secondment of qualified BDO QI subject matter experts on-site to perform QI documentation reviews as part of the first line of defense
  • Performance of second-line-of-defense internal controls

IRS liaison and portal management

When the IRS issues requests or follow-up questions, we help clients respond with clear, technically robust and well-documented explanations.

Our support includes:

  • Preparation of responses to IRS queries
  • Management of dialogue with the IRS
  • Support with IRS portal processes
  • Assistance with issue resolution and remediation strategy

Why BDO

BDO brings specialist QI expertise, practical execution capabilities and experience in dealing with U.S. tax authority interactions. We can support your first and second lines of defense, act as an additional expert resource, or take charge of defined QI workstreams.

Whether you need a QI Periodic Review, reporting support, remediation assistance or ongoing advisory, BDO helps you reduce compliance risk, optimise your operational processes and manage your QI obligations with confidence.


Key Contacts

Sylvie Maestri

Sylvie Maestri

Partner - Tax Regulatory Services
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