U.S. Chapter 3

QI and NQI regulations

Whether you are a qualified intermediary or a non-qualified intermediary, we can help you navigate the rules on withholding, depositing and reporting U.S.- sourced FDAP income


How we support financial institutions with their U.S. Chapter 3 cross-border withholding tax obligations:

Exposure Map Report

If you receive U.S.-sourced income on behalf of your non-US clients we can provide an exposure map report that will give you:

  1. A clear picture of how your firm is impacted by Chapter 3
  2. An overview of the operational choices available to you
  3. Practical recommendations to remediate any issues

Compliance Manual Development

We can provide expert support to help your team build the comprehensive compliance manual that allows you to manage risk and operate efficiently.

We make sure that your compliance manual communicates your policies and procedures clearly to staff at all levels within the firm and can be easily adapted to reflect any operational changes.


We can deliver bespoke training to help your staff understand what it means to be a QI or NQI, and how the Chapter 3 regulations impact their role.

We can provide training remotely via video call or on site. All courses are tailored to your specific needs and can be delivered as high-level briefing sessions or operational and compliance deep dives.

Interim Compliance Review

Our interim compliance reviews help QIs to assess their current level of compliance and identify issues that need to be resolved or areas for improvement.

We review a sample of accounts, your compliance manual and related materials, and conduct interviews with key members of staff to give you a holistic and expert view of the adequacy and effectiveness of your controls.

QI Periodic Review

We can carry out your triennial QI Periodic Review remotely and deliver an accessible report that provides everything your Responsible Officer will need to make their certification of controls to the IRS.

We can also deliver training to your internal audit function so they can conduct your Periodic Review in house.

Retained Subject Matter Expertise

We can be on hand to answer day-to-day operational and compliance questions about the Chapter 3 regulations, either on an ad hoc basis or as your retained subject matter experts.

We provide non-legally binding opinion that is practical and to the point, so your operations and compliance teams can make quick, informed decisions and get on with the job.

Start your journey with TConsult

Get an expert review of your current level of compliance with U.S. Chapter 3 and an action plan to help you choose the right path for your firm.


“QI compliance is a team sport – everyone needs to understand the role they play and how it fits into your broader compliance strategy.”

Stuart Lipo, Senior Consultant


+44 (0) 1252 413551