IRS requires renewal for certain FATCA FFI agreements

The IRS has issued a press release advising Foreign Financial Institutions (FFI) with FFI agreements which expired on December 30th, 2016 to renew their FFI agreement by July 31st, 2017.

Failure to do so will result in the FFI being treated as having terminated their FFI agreement which may result in being removed from the FFI list.

The Table below provides a summary of the types of entities required to renew their FFI agreement (extracted from the IRS press release):

Renewal of FFI Agreement

Financial Institution’s FATCA Classification in its Country/ Jurisdiction of Tax Residence

Type of Entity

FFI Agreement Renewal Required?

Participating Financial Institution not covered by an IGA; or a Reporting Financial Institution under a Model 2 IGA

Participating FFI not covered by an IGA

Yes

Reporting Model 2 FFI

Yes

Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under a Model 1 IGA)

Reporting Model 1 FFI operating branches outside of Model 1 jurisdictions

Yes, on behalf of branches operating outside of Model 1 jurisdictions (other than related branches)

Reporting Model 1 FFI that is not operating branches outside of Model 1 jurisdictions;

No

Registered deemed-compliant FFI (regardless of location)

No

None of the above

Sponsoring entity

No

Direct reporting NFFE

No

Trustee of Trustee-Documented Trust

No

Link to FATCA News and Information Bulletin 5/5/17: https://content.govdelivery.com/accounts/USIRS/bulletins/1987aea#First

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