Limited FFIs and Limited Branches
Pursuant to Notice 2015-66 (2015-41 I.R.B. 541), the transitional period for limited FFI and limited branch statuses expires on December 31, 2016. Once limited FFI status expires, participating FFIs and registered deemed-compliant FFIs (other than FFIs covered by an IGA) that are in an expanded affiliated group with a limited FFI will no longer be able to obtain or retain their status as a participating or registered deemed-compliant FFI. In addition, participating FFIs (other than FFIs covered by an IGA) that have limited branches, and any branches of the FFI that have participating FFI status under the FFI agreement, will no longer be able to obtain or retain their participating FFI statuses. After December 31, 2016, all new and existing limited FFI and limited branch registrations will be placed in “registration incomplete” status.
Renewal of Qualified Intermediary (QI), Withholding Foreign Partnership (WP), and Withholding Foreign Trust (WT) Agreements
Beginning with 2017 renewals, QIs, WPs, and WTs will no longer be able to renew their QI, WP, or WT agreement using Form 8957. QIs, WPs, and WTs intending to renew their agreement for 2017 (including QIs renewing and seeking to act as QDDs) will need to do so through the QI/WP/WT Application and Account Management System, which the IRS anticipates making available in mid-December 2016. Accordingly, users of Form 8957 should not complete Part 3 (Renewal of Agreement for QIs, WPs, or WTs) of the form. New applications for QI, WP, or WT status will also be submitted through the QI/WP/WT Application and Account Management System beginning in mid-December 2016.