IRS Form 14345 – Foreign financial institutions, partnerships, and trusts handling U.S.-source income must navigate complex U.S. withholding and reporting rules under Chapters 3 and 4 of the Internal Revenue Code (including FATCA). IRS Form 14345 serves as the key application for entities seeking Qualified Intermediary (QI), Withholding Foreign Partnership (WP), or Withholding Foreign Trust (WT) status. This streamlined status simplifies obligations while allowing assumption of primary withholding responsibilities.
Download the official PDF here: IRS Form 14345 (Rev. October 2016).
This guide draws exclusively from current IRS sources (as of February 2026), including the Qualified Intermediary Program page, the 2023 QI Agreement (Rev. Proc. 2022-43), the QI/WP/WT Application and Account Management System (QAAMS) User Guide, and related FAQs. It explains eligibility, benefits, the modern online application process, required information, and post-approval responsibilities.
What Is IRS Form 14345?
Form 14345, titled “Application for Qualified Intermediary, Withholding Foreign Partnership, or Withholding Foreign Trust Status” (OMB No. 1545-1597, Rev. October 2016), collects essential details about the applicant entity. Although the paper form remains available for reference, the IRS now processes all applications exclusively through the secure online Qualified Intermediary, Withholding Foreign Partnership, and Withholding Foreign Trust Application and Account Management System (QAAMS).
The form (and the QAAMS questions modeled on it) requires the entity to demonstrate it has adequate resources, policies, and procedures to comply with the QI, WP, or WT agreement. Key sections typically include:
- Applicant name, address, and eligibility category (e.g., Non-U.S. Financial Institution, Non-U.S. Clearing Organization, Branch of U.S. Financial Institution, or Other).
- Description of business activities.
- New account opening and documentation procedures.
- Responsible officer and contact person details.
- Whether the applicant will assume primary withholding responsibility.
- External auditor information (if applicable).
- Confirmation that Form SS-4 (for EIN) has been submitted.
- History of prior QI/WP/WT applications.
Attachments historically required (and still mirrored in QAAMS uploads) include a letter of intent, business description (Attachment A), account opening procedures (Attachment B), and Form 2848 (Power of Attorney) where needed.
Understanding the Qualified Intermediary (QI) Program
The QI Program allows eligible foreign entities to enter into a formal agreement with the IRS to act as a withholding agent for U.S.-source fixed or determinable annual or periodical (FDAP) income (e.g., interest, dividends, royalties) paid to their account holders, partners, beneficiaries, or owners.
- Qualified Intermediary (QI): A foreign intermediary (typically a financial institution) that assumes primary Chapters 3 and 4 withholding and reporting responsibilities. QIs can also elect Qualified Derivatives Dealer (QDD) status to handle dividend equivalent payments under Section 871(m) without withholding in a principal capacity.
- Withholding Foreign Partnership (WP): A foreign partnership that assumes primary withholding and reporting on distributions or distributive shares of U.S.-source income to its direct and indirect partners.
- Withholding Foreign Trust (WT): A foreign trust that assumes similar primary obligations for distributions to beneficiaries or owners.
These agreements integrate with FATCA (Chapter 4) and allow streamlined use of withholding rate pools on Form W-8IMY instead of providing full documentation for every underlying beneficial owner.
Current governing documents:
- 2023 QI Agreement (effective for most agreements on or after January 1, 2023; expires December 31, 2028 unless terminated).
- Separate WP/WT agreements (Rev. Proc. 2017-21).
Who Is Eligible to Apply?
Eligibility requires demonstrating compliance capability under Treas. Reg. §1.1441-1(e)(5)(ii) and Chapter 4 status:
- Participating FFIs, registered deemed-compliant FFIs (including under IGAs), or certain other entities.
- Foreign clearing organizations.
- Foreign branches of U.S. financial institutions.
- Foreign partnerships or trusts seeking WP/WT status (with specific rules for reverse hybrids, simple/grantor trusts, and pooled vs. non-pooled reporting).
- Qualified Derivatives Dealers (additional QDD-specific procedures and systems required).
Ineligible entities include nonparticipating FFIs, most territory financial institutions, and entities without adequate KYC/AML procedures in IRS-approved jurisdictions.
Applicants must have:
- FATCA registration (Form 8957) and GIIN (except certain central banks or NFFEs).
- Robust documentation, withholding, reporting, and periodic review procedures.
- No unresolved defaults on prior agreements.
Key Benefits of QI, WP, or WT Status
- Simplified Withholding & Reporting: Assume primary responsibility — withhold at appropriate rates (including treaty benefits) and report via Forms 1042/1042-S without passing full beneficial owner documentation upstream.
- Client Privacy Protection: Avoid disclosing underlying client identities to upstream withholding agents.
- Reduced Compliance Burden: Use withholding rate pools and streamlined Form W-8IMY.
- QDD Election (for QIs): Avoid withholding on certain Section 871(m) payments when acting as principal.
- Section 1446(a)/(f) Coverage: Optional for publicly traded partnerships.
- Public Verification: Approved entities appear on the quarterly IRS QI List (name, QI-EIN last two digits, GIIN, country, QDD status).
Step-by-Step Application Process via QAAMS (2026)
Paper submissions are no longer accepted for new applications. All processes occur through the secure QAAMS portal.
- Gather Information (per QAAMS User Guide and Form 14345 structure):
- Entity legal name, country of organization, FATCA ID/GIIN, address.
- Eligibility type (QI/WP/WT) and Chapter 3/4 status.
- Business description and new account opening/KYC procedures.
- Approximate account holder numbers and U.S. asset values by category.
- Responsible officer and contact person details (names, phones, emails — must match exactly for access).
- Withholding intent (primary Chapters 3/4 and/or 1099/backup withholding).
- Branches (up to 150), PAI agreements, QDD transaction details (if applicable).
- Compliance history, prior applications, and any events of default.
- Create QAAMS Account:
- Only authorized users (Responsible Officer, Contact Person, up to 2 POAs) can access.
- Use unique emails and matching names.
- Gather info via the official pre-creation checklist PDF.
- Submit Application in QAAMS:
- Log in → Select “Apply for QI, WP, or WT status.”
- Complete multi-part questionnaire (system auto-directs based on entity type).
- Upload up to 10 files (≤10MB each: PDF, DOC, XLS, JPG, etc.), including:
- Form SS-4 (required).
- Detailed business and account opening descriptions.
- Form 2848 (if POA).
- QDD-specific system descriptions.
- Any remediation or compliance history explanations.
- Certify under penalties of perjury and submit.
- Processing and Effective Date:
- IRS reviews for adequate resources/procedures.
- Timely applications (generally by March 31 for January 1 effectiveness, subject to current IRS announcements) receive priority.
- Approved entities receive a QI-EIN (or WP/WT-EIN) and appear on the quarterly QI List after ~2 months.
Deadlines: Check IRS announcements for annual application windows (e.g., past cycles used September 30 cutoffs for certain years). Late applications may receive later effective dates. Renewals and certifications occur in system-notified open periods.
Post-Approval Responsibilities
- Maintain a compliance program with periodic reviews (internal or external) and annual certifications by the Responsible Officer.
- Withhold and report accurately (Forms 1042-S, 1042, 1099, 8966 as applicable).
- Update QAAMS for changes (branches, contacts, PAI additions).
- Appear on and verify accuracy in the public QI List.
- Face potential termination for material failures (90-day cure period).
Common Questions About Form 14345 and QI Status
Is Form 14345 still required?
The information it collects is now entered directly into QAAMS, which is explicitly based on Form 14345.
Do I need a separate FATCA registration?
Yes, in most cases, before or alongside the QI application.
Can I apply for QDD status?
Yes, as part of the QI application with supplemental QDD details.
Where do I find approved KYC rules?
On the IRS List of Approved Know-Your-Customer Rules.
Final Tips for Successful Application
- Review the full 2023 QI Agreement and QAAMS User Guide (Publication 5262) before starting.
- Ensure all contact details match exactly to avoid access issues.
- Prepare robust descriptions of your AML/KYC and withholding systems — this is the core of IRS approval.
- Consult a qualified tax advisor or attorney experienced in international withholding for complex structures.
For the most current deadlines, system access, or questions, visit these trusted IRS resources:
- Qualified Intermediary Program
- Apply/Renew via QAAMS
- QI List (updated quarterly)
- QI System FAQs
- General QI FAQs
Obtaining QI, WP, or WT status via Form 14345 (through QAAMS) can significantly reduce administrative burdens for cross-border payments. Always verify the latest requirements directly on IRS.gov, as procedures and deadlines may be updated annually.
This article is for informational purposes only and does not constitute tax or legal advice.