Putting the QI rules into practice

In last month’s article, the authors discussed the tricky question of what constitutes a QI and recently issued guidance by the IRS. Part two of this article answers frequently asked questions about the day-to-day application of the QI rules and addresses the need not to be complacent, By Philip Marcovici and Marnin Michaels of Baker & McKenzie’s Zurich office, Thomas O’Donnell in the Paris office and David Balaban and Peter Connors of Baker & McKenzie in New York