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FATCA Glossary of Acronyms

Foreign Account Tax Compliance Act

A comprehensive glossary of Foreign Account Tax Compliance Act (FATCA) acronyms will help you understand all the terms surrounding FATCA. Click on the alphabet to find a term or download the full glossary.

For more information please contact a FATCA Leader or click here.

A
AML Anti-Money Laundering
B
Bad FFI A non participating FFI (NPFFI)
C
CFC Controlled Foreign Corporation
Chapter 4 Chapter 4 of Subtitle A of the Internal revenue Code contains the FATCA legislation
Chapter 4 withholding Refers to the 30% FATCA withholding
CIP Customer Identification Program
D
Deemed Compliant FFI Local banks, local FFI members of PFFIs and certain investment vehicles may be Deemed Compliant by the IRS for FATCA if they satisfy certain criteria
Documentation Documentation includes all information recorded in written or electronic form, stored in connection with a financial account
E
ECI Effectively Connected Income
EIN Employer Identification Numbers
Excepted NFFE A class of NFFEs that are outside of the scope for FATCA. They include publically traded non-U.S. companies, foreign governments, international organisations, foreign central banks
F
FATCA Foreign Account Tax Compliance Act. Refers to Chapter 4 of the U.S. Internal Revenue Code, which was enacted by the Hiring Incentives to Restore employment (HIRE) Act on March 18, 2010. FATCA requires non-U.S. foreign financial institutions (FFIs) and non-U.S. non-financial entities (NFFEs) to identify and disclose their U.S. account holders and members. Should they fail to do this, they will become subject to a new 30% U.S. withholding tax with respect to any payment of U.S. source income and proceeds from the sale of equity or debt instruments of U.S. issuers (i.e., withholdable payments).
FDAP Income which is Fixed or Determinable, Annual or Periodical derived from gains, profits, and income, and includes payments such as interest (including original issue discount), dividends, rents, salaries, wages, premiums, and annuities.
FFI Foreign Financial Institution — any FI which is not located in the USA
FFI Agreement The agreement between the FFI and the IRS that requires the FFI to identify U.S. accounts and to report financial information on U.S. accounts to the IRS.
FI Financial Institution — any entity that (i) accepts deposits in the ordinary course of a banking or similar business, (ii) holds financial assets for the account of others as a substantial portion of its business, or (iii) is engaged (or holding itself out as being engaged) primarily in the business of investing, reinvesting, or trading securities, partnership interests, commodities or similar financial instruments
Financial Account A depository or custodial account maintained by an FFI and any non-publicly traded debt or equity interest in an FFI
Foreign Person A non-U.S. Person
FWP Foreign Withholding Partnership
FWT Foreign Withholding Trusts
G
Grandfathered Obligation An obligation that is outstanding on March 18, 2012 (two years from the date that FATCA was signed into law)
H
HIRE Act Hiring Incentives to Restore Employment; FATCA was enacted as part of HIRE
I
Indicia A U.S. legal term meaning indication. In the context of FATCA, indicia refer to evidence or indications that an account holder might be a U.S. person
IRS The United States Internal Revenue Service
K
KYC Know-Your-Customer
N
NFFE Non-Financial Foreign Entity — a foreign entity that is not a financial institution, usually a corporation or company
NPFFI A Non-Participating FFI — an FFI that is not a participating FFI, or a Deemed Compliant FFI or otherwise excluded from the application of FATCA. Sometimes called a Bad FFI
NQI Non Qualifying Intermediary
P
Passthru Payment Any Withholdable Payment or other payment to the extent attributable to a Withholdable Payment
PFFI Participating FFI — an FFI that has entered into 1471(b) agreement with the IRS under FATCA
PFIC Passive Foreign Investment Company
PPP Passthru Payment Percentage — the ratio of a PFFI's U.S. to total assets
Pre-existing account Any financial account held prior to the date the FFI's agreement with the IRS comes into force
Q
QFFI A Qualifying FFI is one which has entered an agreement with the IRS under FATCA. Essentially the same as a PFFI
QI Qualified Intermediary
R
Recalcitrant Account Holder An account holder who fails to comply with reasonable requests for information in accordance with IRS mandated verification and due diligence procedures to identify U.S. Accounts, to provide a name, address and TIN or fails to provide a bank secrecy waiver upon request
S
Specified U.S. Person A U.S. citizen or resident alien, privately owned U.S. Corporation or U.S. Owned Foreign Entity
Substantial U.S. Owner A U.S. owner that has a more than 10% interest in an NFFE
T
TIN Taxpayer Identification Number
U
U.S. Account A financial account held by a specified U.S. person or by an entity that, directly or indirectly, has one or more "substantial" U.S. owners
U.S. Indicia Data which is indicative of an account holder being a U.S. Account, for example U.S. place of birth, U.S. passport, green card, U.S. address, substantial U.S. presence, regular payments to or from a USFI
U.S. Owned Foreign Entity A foreign entity which has one or more Substantial U.S. Owners
U.S. Person An account holder who is a U.S. citizen or taxpayer. Includes U.S. entities and other qualifying persons such as Green Card holders
USFI U.S. Financial Institution — a Broker or Dealer, Investment Fund, Investment Adviser, Bank, Trust Companies based in the USA
W
Withholding The act of holding some of the value of a payment, for the purpose of paying tax.
Withholdable Payment (i) any payment of interest (including any original issue discount), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, and other fixed or determinable annual or periodical gains, profits, and income, if such payment is from sources within the United States, and (ii) any gross proceeds from the sale or other disposition of any property of a type which can produce interest or dividends from sources within the United States.
Withholding Agent An individual, corporation, partnership, trust, association, or any other entity, including any foreign intermediary, foreign partnership, or U.S. branch of certain foreign banks and insurance companies that has control, receipt, custody, disposal, or payment of any withholdable payment

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