April 9, 2013: Foreign Financial Institution List Schema and Extensible Markup Language (XML) Test Files
Foreign Account Tax Compliance Act (FATCA)
The IRS released the Foreign Financial Institution (FFI) List Schema and Extensible Markup Language (XML)1 Test Files to allow withholding agents and other interested parties to prepare systems and procedures to validate Global Intermediary Identification Numbers (GIINs) provided by account holders and payees.
Under FATCA, withholding agents will need to validate GIINs against the published IRS FFI List to ensure that entities that are required to register with the IRS are FATCA compliant. Moreover, withholding agents will need to ensure that any GIINs removed from the list are captured and that the relevant FFIs are treated as non-participating FFIs within one year of such removal (or on the date the withholding agent knows of the change).
The published schema contains information on the FFI List that will be published, while the XML test files contain dummy data records for testing purposes. The XML test files also illustrate the format and data that will be included on the published FFI List. The following is the information provided in the XML test file:
|GIIN||Financial Institution Name||Country|
|98Q96B.00000.LE.250||Test Bank One||France|
|98Q96B.00001.ME.276||Test Bank Two||Germany|
|8124H8.00000.SP.208||Test Bank Three||Denmark|
|C54S47.99999.SL.276||Test Bank Four||Germany|
|126BM7.00000.LE.826||Test Bank Five||United Kingdom|
|126BM7.00001.ME.208||Test Bank Nine||Denmark|
|126BM7.00002.ME.276||Test Bank Ten||Germany|
|SE19K4.99999.SL.250||Test Bank Eleven||France|
The IRS anticipates publishing the FFI List monthly beginning December 2013, and the first list to be published in December 2013 will contain the GIIN for FFIs that register by October 25, 2013. Withholding agents, future participating FFIs, and other affected parties should begin analyzing the XML information and test files, and begin developing processes and procedures to comply with the GIIN validation requirements.
We will keep you informed as the IRS releases additional information and guidance, and as we process the full impact of the newly released XML schema.
1 XML is a standard computer protocol for transportation and storage of data.
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