U.S.A.: FATCA : Registration : Update
The U.S. Internal Revenue Service (IRS) has released updated guidance on the FATCA financial institution registration.
The updated guidance reminds financial institutions of the different steps to take on the web portal in order to register and obtain a Global Intermediary Identification Number (GIIN), as well as the timeline, as originally announced in their Notice 2013-34.
With regard to payees that are a Reporting Model I financial institutions, it is confirmed that verification of a GIIN is not required for payments made before 1 January 2015. As a consequence, such entities will not need to register or obtain a GIIN until on or about 22 December 2014 to ensure inclusion on the IRS FFI list by 1 January 2015.
In addition, it indicates that the IRS and the U.S. Treasury Department anticipate publishing the final FFI agreement before 1 January 2014 and the final QI, WP and WT agreements in early 2014.
The above information will be published in Internal Revenue Bulletin 2014-1 on 6 January 2014.
We continue to monitor the implementation of FATCA and will provide more information as it becomes available.
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