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 PDF has also been updated to include steps for FFIs to renew their FFI agreement.
