Renewal of FFI Agreements Required by July 31, 2017
All Foreign Financial Institutions (FFIs) not covered by an IGA and all Reporting FFIs under a Model 2 IGA must renew their FFI Agreement by July 31, 2017. This should be completed through the IRS FATCA registration website where the original registration was performed and a GIIN obtained.
Any agreements not completed by the due date will result in the FFI being considered nonparticipating as of January 1, 2017 and removed from the FFI issued by the IRS. This will result in a 30% withholding on any US source withholdable payments made by a US withholding agent (e.g., a US bank or financial institution).
Revenue Procedure 2017-16
A new FFI agreement has been issued as part of the above mentioned Revenue Procedure and supersedes Rev. Proc. 2014-38, which was the old agreement that expired on December 31, 2016. There is a table (see below) as part of the FAQ section of the website that sets forth the FFIs that must renew their agreements. It is FAQ Q8 under the Registration Update. This would include Model 2 FFIs in Austria, Bermuda, Japan and Switzerland. Non-IGA jurisdictions would include FFIs in Argentina and Russia, among others.
Call Moore Stephens Doeren Mayhew at 248.244.3060 if you have questions about whether your FFI needs to renew its Agreement with the IRS, or you need assistance with accessing the IRS registration website to renew the Agreement.
Victor (Sandy) Jose, CPA
For more than 35 years, Victor (Sandy) Jose has assisted clients with their inbound and outbound investments, Foreign Account Tax Compliance Act (FATCA) compliance, Offshore Voluntary Disclosure Program projects, as well as other withholding and reporting projects. Sandy has extensive and broad based global experience in the automotive and manufacturing industries. Contact Sandy at firstname.lastname@example.org or (248) 244-3082.