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Internal Revenue Bulletin:  2014-29 

July 14, 2014 


Rev. Proc. 2014–38Rev. Proc. 2014–38

Revenue Procedure 2014–38 updates the FFI Agreement applicable to foreign financial institutions (FFIs) wishing to enter into an FFI Agreement with the IRS to be treated as a participating FFI under section 1471(b) of the Code. Rev. Proc. 2014–38 also provides guidance to FFIs and branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA) on complying with the terms of the FFI Agreement, as modified by the Model 2 IGA. Rev. Proc. 2014–38 updates the FFI Agreement to reflect the temporary regulations released on February 20, 2014, under chapters 3, 4, and 61 of the Code, and section 3406. Rev. Proc. 2014–38 modifies and supersedes Rev. Proc. 2014–13.

Rev. Proc. 2014–39Rev. Proc. 2014–39

Revenue Procedure 2014–39 updates the Qualified Intermediary (QI) agreement published in Rev. Proc. 2000–12, 2000–1 C.B. 387 (as amended) applicable to foreign intermediaries that wish to enter into a QI withholding agreement with the IRS under § 1.1441–1(e)(5). The QI agreement is being updated to reflect the enactment of Chapter 4 (§§ 1471–1474) of the Code, and the issuance of regulations under section 3406 and chapters 3, 4, and 61 of the Code. Rev. Proc. 2014–39 supersedes Rev. Prov. 2000–12 with respect to the requirements of a QI that apply on or after June 30, 2014, and is effective as of the date of public release. The effective date of this revenue procedure is June 27, 2014.

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