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August 19, 2013: IRS Opens FATCA Registration System

Foreign Account Tax Compliance Act (FATCA)


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IRS opens FATCA registration system and publishes additional guidance

As announced in IRS Notice 2013-43, the IRS has opened the FATCA Registration System. The IRS has also provided additional registration guidance including a FATCA registration overview, a detailed 75 page FATCA Registration Online User Guide, tips for logging into the FATCA Registration System, instructions for the Form 8957 paper registration form, and a document detailing the format of the Global Intermediary Identification Number (GIIN) used to identify FATCA compliant entities. On the “FATCA Registration Resources and Support Information” page (link to the site is below), the IRS affirms the registration timeline outlined in 
Notice 2013-43.

At first glance, the system is fairly straightforward and consistent with recent IRS presentations. Two key aspects of the system stand out. First, the instructions confirm that an expanded affiliated group can have more than one lead FI allowing the group to create multiple sub-groups within its expanded affiliated group.

Second, there is not a full length “FFI Agreement” as the IRS has previously stated would be published in a Revenue Procedure before the opening of the registration site. The Agreement is more of a broad and open-ended certification from the entity’s responsible officer that the FFI will comply with “the terms and conditions reflected in regulations, intergovernmental agreements, and other administrative guidance to the extent applicable to the Financial Institution based on its status in each jurisdiction in which it operates.” A screenshot of the responsible officer certification or the “FFI Agreement” is directly below.

FFI Agreement / Responsible Officer Certification

We will provide additional updates as we continue to analyze the newly released guidance and registration system. The IRS published guidance is attached and the registration system can be accessed from this link: http://www.irs.gov/Businesses/Corporations/FATCA-Registration.

The full article and attachments of the IRS registration guidance are available for download. For more information please contact a Deloitte FATCA Leader or click here.

As used in this document, “Deloitte” means Deloitte Tax LLP, a subsidiary of Deloitte LLP. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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