The Internal Revenue Service announced today that its FATCA FFI Registration system has been updated to allow foreign financial institutions to renew their FFI agreement with the IRS. Those financial institutions that are required to renew their FFI agreement and do not by July 31, 2017, will be treated as having terminated their FFI agreement as of January 1, 2017, and may be removed from the FFI list maintained on the IRS website.
The table below provides a general overview of the types of entities that are required to renew their FFI agreement.
|
Renewal of FFI Agreement |
|
Financial Institution’s FATCA Classification in its Country/ Jurisdiction of Tax Residence |
Type of Entity |
FFI Agreement Renewal Required? |
|
Participating Financial Institution not covered by an IGA; or a Reporting Financial Institution under a Model 2 IGA |
Participating FFI not covered by an IGA |
Yes |
|
Reporting Model 2 FFI |
Yes |
|
Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under a Model 1 IGA) |
Reporting Model 1 FFI operating branches outside of Model 1 jurisdictions |
Yes, on behalf of branches operating outside of Model 1 jurisdictions (other than related branches) |
|
Reporting Model 1 FFI that is not operating branches outside of Model 1 jurisdictions; |
No |
|
Registered deemed-compliant FFI (regardless of location) |
No |
|
None of the above |
Sponsoring entity |
No |
|
Direct reporting NFFE |
No |
|
Trustee of Trustee-Documented Trust |
No |
The system will notify all approved financial institutions of the renewal open period and due date to renew the FFI agreement. The due date for all renewals is July 31, 2017. The system instructions and online help have been updated to address the renewal of FFI Agreement function. The FATCA Registration User Guide has also been updated to include steps for financial institutions to renew their FFI agreement.
Along with system fixes, the update within the registration application includes the removal of the classification of “limited” for financial institutions and branches. This classification option will no longer be available for new or renewal applicants.
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