Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a result, all QI, WP, or WT agreements currently in effect will expire as of December 31, 2013. A revised QI agreement and WP/WT agreement are expected to be published in a Revenue Procedure no later than July 15, 2013.
FFIs registering with the IRS to obtain participating FFI or registered deemed-compliant status will be able to do so through a secure online FATCA Registration Portal (Portal). The Portal is available for only QIs, WPs, and WTs seeking to renew their agreements (including FFIs that obtain such status during 2013).
In order to ensure that QI, WP, or WT status is obtained prior to the date the registration portal opens, no later than July 15, 2013, financial institutions seeking such status must submit the appropriate QI, WP, or WT application and all required attachments no later than May 3, 2013.
Applications will be accepted until November 15, 2013, with respect to obtaining QI, WP, or WT status for the 2013 year. An application received on or before this date will be processed in time to permit the desired registration status prior to December 31, 2013.
If you have any questions, please contact Darren Mills at 646.205.9352 or email@example.com.
The views expressed in this article are those of the authors and do not necessarily reflect the position or policy of Berkeley Research Group, LLC.
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