FATCA - Announcement 2014-1 updates financial institution registration 

December 13: The IRS today released an advance copy of Announcement 2014-1 as an update on the FATCA financial institution registration process.

The IRS made available the FATCA registration website for financial institutions (FIs) in August 2013. This was intended to allow FIs to begin the process of creating accounts and entering registration information. All information entered since August 19, 2013, has been automatically saved in the registration system and associated with a financial institution’s FATCA account.

Announcement 2014-1 [PDF 21 KB] states that all registrations prior to January 2014—including registrations submitted as final before December 31, 2013—will be treated as initiated but unsubmitted.

Thus, on or after January 1, 2014, every registering financial institution must:

  • Revisit its account, make edits to its information if necessary
  • Sign its FFI agreement if registering as a participating FFI
  • Submit its registration information as final

Any FI submitting its registration information on or after January 1, 2014, may subsequently choose to revoke its status by revisiting its account and deleting its registration (if its GIIN has not yet been issued) or cancelling its registration (if its GIIN has already been issued).

What’s next?

  • The IRS and Treasury anticipate that the final FFI agreement will be published prior to January 1, 2014.

  • Final qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) agreements will be published in early 2014.

  • Any FI seeking to renew its status as a QI, WP, or WT must do so during the registration process (i.e., by answering Questions 6, 9c, 13, 14, and 15).

  • Any QI, WP, or WT that does renew its status prior to the finalization of the QI, WP, and WT agreements will be treated as having accepted the revised terms of the applicable agreement, effective on June 30, 2014, for QIs, WPs, and WTs that receive a GIIN prior to July 1, 2014.

  • Any QI, WP, or WT may terminate its status at any time by delivery of a notice of termination in accordance with the terms of the applicable agreement.

Today’s announcement states that all other dates relevant to registration and publication of the IRS FFI List as described in Notice 2013-43 remain unchanged.

The IRS reported that it will electronically post the first IRS FFI List by June 2, 2014, and any FI seeking to be included on the June 2014 IRS FFI List must finalize its registration by April 25, 2014.

Verification of a GIIN is not required for payments made prior to January 1, 2015, with respect to any payee that is a reporting Model 1 FI. Thus, while reporting Model 1 FIs will be able to register and obtain GIINs on or after January 1, 2014, they will not need to register or obtain GIINs until on or about December 22, 2014, to allow for inclusion on the IRS FFI list by January 1, 2015.

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