Coping with the QI burden: part I

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Coping with the QI burden: part I

September 30 2000

In the first of two articles, Marnin Michaels, David Balaban, Peter Connors, Philip Marcovici, and Thomas O’Donnell of Baker & McKenzie review the stringent requirements of the new qualified intermediary regime in the US and suggest ways to address them

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

FeatureSponsoredITR MagazineOctober 2000
more across site & shared bottom lb ros

More from across our site

Indirect Tax
Brazil tax money
Advisers hope Brazil and US reach agreement on Trump tariffs
The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
Sam Sholli, July 18 2025
Direct Tax
germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.
This week in tax: Germany still ‘committed’ to pillar two despite chancellor’s condemnation
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
Tom Baker, July 18 2025
Direct Tax
OECD image.jpeg
OECD unveils pillar two safe harbour for highly taxed MNEs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
Tom Baker, July 17 2025
Direct Tax
Big Ben at golden hour
Too many HMRC compliance investigations last too long, committee warns
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Sam Sholli, July 17 2025
Transfer Pricing
hmrc.jpg
UK TP proposals could ‘double compliance costs’, tax firm warns
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
Tom Baker, July 16 2025
Direct Tax
OECD image.jpeg
Pillar two no longer has a future, German chancellor claims
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Sam Sholli, July 16 2025
Direct Tax
Pillar two is revising global tax competition with a 15% minimum tax rate
Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
Ralph Cunningham, July 16 2025
Direct Tax
amory_heine resized.jpg
‘Pro bono is a must’: Amory Heine on giving back
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
July 15 2025
Direct Tax
Hillier, Craig_ColorPortrait.jpg
‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
Sam Sholli, July 14 2025
Direct Tax
London- HM Revenue and Customs building on Whitehall, UK Governm
HMRC believes US companies underpaid £8.8bn in tax: accountancy group
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
Sam Sholli, July 14 2025
Gift this article