Reminder: Oct. 24 is Deadline for Foreign Financial Institutions Participating in FATCA to Check Their Renewal Requirement

 

IR-2017-174, Oct. 13, 2017

WASHINGTON — Internal Revenue Service officials today urged foreign financial institutions to quickly renew their Foreign Financial Institution (FFI) agreements if required. If an FFI is required to renew its agreement and fails to do so by Oct. 24, 2017, the group will be removed from the November FFI list and will be subject to a 30 percent withholding tax on certain U.S. source payments.

An FFI must determine whether it is required to renew its FFI agreement. The table below is provided to assist FFIs with the determination. If an FFI has determined that it is required to renew, the FFI should log into the FATCA FFI Registration system and click on the link to “Renew FFI Agreement.” The FFI will need to verify, update (if needed), and submit their registration to renew their FFI agreement.

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

 
The system instructions and online help text have been updated to include instructions for the Renewal of FFI Agreement. The FATCA Registration User Guide has also been updated to include steps for FFIs to renew their FFI agreement.