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.