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April 9, 2013: Foreign Financial Institution List Schema and Extensible Markup Language (XML) Test Files

Foreign Account Tax Compliance Act (FATCA)


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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.00000.BR.826 Branch United Kingdom
98Q96B.00000.BR.036 Branch Australia
98Q96B.00000.BR.076 Branch Brazil
98Q96B.00000.BR.818 Branch Egypt
98Q96B.00001.ME.276 Test Bank Two Germany
98Q96B.00001.BR.826 Branch United Kingdom
8124H8.00000.SP.208 Test Bank Three Denmark
C54S47.99999.SL.276 Test Bank Four Germany
C54S47.99999.BR.208 Branch Denmark
126BM7.00000.LE.826 Test Bank Five United Kingdom
126BM7.00000.BR.250 Branch France
126BM7.00001.ME.208 Test Bank Nine Denmark
126BM7.00002.ME.276 Test Bank Ten Germany
126BM7.00002.BR.344 Branch Hong Kong
SE19K4.99999.SL.250 Test Bank Eleven France
76GHU9.00000.BR.036 Branch Australia
76GHU9.00000.BR.818 Branch Egypt
92YNJG.00000.BR.076 Branch Brazil

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.

Full article is available for download. For more information please contact FATCA Leader or click here.

1 XML is a standard computer protocol for transportation and storage of data.

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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