Foreign Financial Institutions in FATCA Need to Check Registrations

The IRS is reminding foreign financial institutions to renew their Foreign Financial Institution (FFI) agreement if required. These FFIs have until Oct. 24, 2017 to complete their renewal. Those that don’t renew their agreements could be removed from the November FFI list and be subject to a 30 percent tax on certain U.S. source payments.

“We’ve worked with foreign financial institutions to implement FATCA registration and information reporting,” said Large Business & International Commissioner Doug O’Donnell. “An important October deadline is approaching that some of these groups might overlook. We urge foreign financial institutions to make sure they timely renew their agreements, using the FATCA FFI Registration System, to avoid losing their status.”‎

Those who are required to renew their FFI agreement and do not by Oct. 24, 2017, will be treated as having terminated their FFI agreement as of January 1, 2017.

All FIs should login to the system for this determination.  For login assistance, review the FATCA FFI Registration system FAQ's.

The FATCA FFI Registration system has been updated to include the ability for FFIs to renew their agreements with the IRS. Once logged into the registration system, a financial institution can determine whether it must renew its FFI agreement using the link to “Renew FFI Agreement.” The following table provides guidance regarding entities required to renew their FFI agreement is provided below to assist FIs with this determination.  Once the determination is made, the system enables an FI to review and edit their registration form as needed. The FI will need to verify and update their registration information and submit 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 updates to the FATCA Registration system include the addition of Renewal of FFI Agreement fields and information on account home pages and the lead's view of member pages. These fields include:

  • FI Renewal of Agreement Due Date
  • Renewal of Agreement Submitted Date
  • Renewal Status

The system instructions and online help have been updated to include instructions for the Renewal of FFI Agreement. The FATCA Registration User Guide has also been updated to include steps for FIs to renew their FFI agreement.

The update within the registration application includes the removal of the classification of limited FFIs and limited branches.  This classification option will no longer be available for new FI applicants or for renewing FIs as the transitional period for the limited FFI and limited branches statuses has expired.

 

 


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