This update supplements the Instructions for Form 8966 to correct and clarify certain references to the reporting requirements of participating FFIs for the 2014 year, including to reflect a correcting amendment to section 1.1471-4(d)(7)(iv)(B) of the temporary chapter 4 regulations (TD 9657). Filers of Form 8966 may rely on this update, which will be incorporated in the next issuance of the instructions to the extent applicable for the 2015 calendar year. On page 6 of the instructions, the second sentence of the paragraph under the heading “Transitional Account Information Reporting Rules for 2014 and 2015—2014 Calendar Year” should be replaced with the following sentence: The PFFI must report any account identified and documented as a U.S. account or an account held by an ODFFI as of December 31, 2014, if such account was outstanding on or after the effective date of the PFFI’s FFI agreement. This replacement sentence removes an incorrect reference to reporting with respect to 2014 by a participating FFI on an account held by a nonparticipating FFI. This reporting applies to calendar years 2015 and 2016 (as described in the bullet header “Account held by a nonparticipating FFI” also on page 6). This replacement sentence also updates the instructions, consistent with the correcting amendment to the temporary chapter 4 regulations (TD 9657), to provide that a participating FFI must report an account that is identified and documented as a U.S. account or an account held by an ODFFI as of December 31, 2014, provided that the account is outstanding on or after the effective date of the participating FFI’s FFI agreement. Page 11 of the instructions describes the requirements for participating FFIs reporting with respect to an account closed or transferred in its entirety by an account holder during a calendar year. The instructions state that for such accounts, a participating FFI must report the amounts paid or credited to the account for the calendar year until the date of closure or transfer and the amount or value withdrawn or transferred from the account in connection with the closure or transfer. This updated sheet clarifies that for 2014 a participating FFI is not required to report amounts paid or credited to the account for the calendar year until the date of closure or transfer. The amount or value withdrawn or transferred from such an account should be reported on line 3 of Part IV (“Account Balance”) (i.e., not on lines 4a through 4d for the reporting of income and gross proceeds). In 2015 and later years, the amounts paid or credited to the account for the calendar year until the date of closure or transfer should be reported on lines 4a through 4d of Part IV, and the amount or value withdrawn or transferred should be reported on line 3 of Part IV.
