December 16, 2013: Update on FATCA Financial Institution Registration (Announcement 2014-1)
Foreign Account Tax Compliance Act (FATCA)
IRS announces update on FATCA financial institution registration in announcement 2014-1
On December 16, 2013, the IRS restated that, as announced in Notice 2013-43, the FATCA Registration System has been accessible since August 19, 2013 and that all information entered into the system is saved. However, final submission cannot be completed until after December 31, 2013 even if already submitted. The IRS and Treasury anticipate that the FFI Agreement will be finalized and published prior to January 1, 2014. Qualified Intermediaries (“QIs”), withholding foreign partnerships (“WP”) and withholding foreign trusts (“WT”) are also reminded that they should renew their QI/WP/WT agreements during the registration process using the appropriate questions.
The IRS reiterated that the dates established in Notice 2013-43 remain unchanged. This may be unwelcome to withholding agents and other affecting parties hoping for further extensions to the FATCA deadlines. Additionally the IRS stated that Model 1 FFIs should register for a Global Intermediary Identification Number (“GIIN” by December 22, 2014 to ensure inclusion on the FFI list by January 1, 2015 (Model 1 FFIs do not have to provide a GIIN to withholding agents prior to January 1, 2015).
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