© 2019

US Withholding Tax

Practical Implications of QI and FATCA


Part of the Global Financial Markets book series (GFM)

Table of contents

  1. Front Matter
    Pages i-xxx
  2. The QI Regulations

    1. Front Matter
      Pages 1-1
    2. Ross McGill
      Pages 3-22
    3. Ross McGill
      Pages 39-62
    4. Ross McGill
      Pages 63-77
    5. Ross McGill
      Pages 79-99
    6. Ross McGill
      Pages 101-117
    7. Ross McGill
      Pages 119-125
    8. Ross McGill
      Pages 127-144
    9. Ross McGill
      Pages 145-154
  3. FATCA

    1. Front Matter
      Pages 155-155
    2. Ross McGill
      Pages 157-163
    3. Ross McGill
      Pages 165-182
    4. Ross McGill
      Pages 183-197
    5. Ross McGill
      Pages 199-216
    6. Ross McGill
      Pages 217-222
    7. Ross McGill
      Pages 223-229
  4. Related Global Tax Initiatives

    1. Front Matter
      Pages 231-231
    2. Ross McGill
      Pages 233-257

About this book


The US QI and FATCA regulations came into being in 2001 and 2010 respectively. They remain today the most challenging cross border tax regulations for financial institutions to comply with and operationalise. There is an increasing trend for financial institutions to become QIs while at the same time, the rules of the QI program become more complex and onerous. Equally, most NQIs have little idea that they are subject to these extra-territorial regulations. The US FATCA anti-tax evasion framework has also evolved through the development of intergovernmental agreements. These are complex and bilaterally jurisdiction specific as well as of multiple types. Most firms are struggling to understand the concepts and how FATCA rules overlap and are affected by QI rules. The original book on this subject by the author continues to be the only book able to explain these regulations in ways that allow financial institutions to understand their compliance obligations and take practical steps to meet them, by hearing about best practice.

This second edition builds on the basic framework of the QI and FATCA frameworks by updating the text to encompass the changes that have occurred since the book’s original publication. This edition will also delete material that has become obsolete or was proposed by the IRS originally but never implemented.


capital compliance European Union (EU) Tax Treaties QI Regulations FATCA Global Tax Initiatives QI Agreement Qualified Derivatives Dealer Status Tax withholding Understand FATCA Comply with FATCA How to account for tax withholding FATCA

Authors and affiliations

  1. 1.TConsult LtdYateleyUK

About the authors

Ross McGill is a well-known author of nine books on international withholding tax and associated regulation as well as anti-tax evasion frameworks (GATCA). McGill sits on several international tax related committees including ISO20022 Securities Evaluation Group. He was an Expert Witness to the European Commission FISCO Group in 2012 and a member of, and editor of, the European Commission Tax Barriers Business Advisory Group Report on in 2013. He has been nominated by multiple financial institutions on two occasions for membership of the US ETAAC and IRPAC tax committees. McGill is Chairman of TConsult Ltd, a specialist consultancy with clients in 15 countries, specialising in providing operational opinion on regulatory compliance to QI, FATCA, AEoI, CRS, MiFID II, GDPR and BEPS amongst others. McGill speaks regularly at conferences including The Network Forum events in Asia, Europe and Africa and has written numerous thought leadership articles for Tax Notes International, the International Bureau of Fiscal Documentation (IBFD) amongst others.

Bibliographic information

  • Book Title US Withholding Tax
  • Book Subtitle Practical Implications of QI and FATCA
  • Authors Ross McGill
  • Series Title Global Financial Markets
  • Series Abbreviated Title Global Financial Markets
  • DOI
  • Copyright Information The Editor(s) (if applicable) and The Author(s), under exclusive license to Springer Nature Switzerland AG 2019
  • Publisher Name Palgrave Macmillan, Cham
  • eBook Packages Economics and Finance Economics and Finance (R0)
  • Hardcover ISBN 978-3-030-23084-5
  • Softcover ISBN 978-3-030-23087-6
  • eBook ISBN 978-3-030-23085-2
  • Edition Number 2
  • Number of Pages XXX, 412
  • Number of Illustrations 44 b/w illustrations, 6 illustrations in colour
  • Topics Financial Accounting
    Business Finance
    Economic Policy
  • Buy this book on publisher's site