Qualified Securities Lender
http://www.irs.gov/irb/2010-24_IRB/ar09.html
Type
Entity
Jurisdiction
U.S.
Sponsor/Regulator
U.S. Internal Revenue Service
Description
A Qualified Securities Lender (QSL) is a foreign financial institution (FFI) that may not be subject to withholding of U.S. tax with respect to any substitute dividend it receives.
Key Facts
An FFI is Qualified Securities Lender only if it satisfies all of the following conditions: it is a bank, custodian, broker-dealer, or clearing organization that is subject to regulatory supervision by a governmental authority in the jurisdiction in which it was created or organized, and is regularly engaged in a trade or business that includes the borrowing of securities of domestic corporations from, and lending of securities of domestic corporations to, its unrelated customers; it is subject to audit by the IRS, in the case of a Qualified Intermediary (QI) that appropriately amends its QI agreement with the IRS, by an external auditor; it files an annual statement on a form prescribed by the IRS certifying that it satisfies the conditions necessary to be a Qualified Securities Lender.