Int'l panels discuss new QI policies, NatWest.

Participants at the ABA Tax Section meeting in August 1999, in Atlanta, GA, discussed the implications of regulations regarding foreign qualified intermediaries (QIs) and the July Court of Federal Claims decision in National Westminster Bank v. United States. Foreign QIs must obtain waivers of nondisclosure law from US payees under IRC section 1441. The Court of Federal Claims decision concerned deductible interest for foreign banks, under IRC section 882, in the US but may have implications for foreign manufacturers of goods who sell products in the US. Taxable income of such foreign manufacturers is subject to IRC section 863(b).