January 13, 2014
The IRS FATCA registration portal is live and includes helpful resources, such as a user guide and "how-to" videos. Several updates have been made to the information available on this website.
Updated User Guide
The FATCA User Guide (IRS Publication 5118) was updated on December 8, 2013. This 122-page version of the user guide replaces the August 2013 version. Recent additions include new tables, appendices and screenshots.
Registration System Changes
On December 8, 2013, the IRS also announced several updates to the FATCA Registration System, including corrections to reported problems, wording updates and enhancements. For a summary of changes, please reference the FATCA Registration System Updates page of the IRS website. For specifics, please refer to Appendix A of the revised FATCA User Guide (IRS Publication 5118), beginning on page 109.
FI Registration Reminders and Updates
The IRS released Announcement 2014-1 on December 16, 2013, to provide an update on the FATCA financial institution (FI) registration process. This announcement reminded firms:
• The IRS FATCA registration website, which went live on August 19, 2013, was launched to help financial institutions begin to familiarize themselves with the FATCA registration process.
• Any information entered before the formal opening of the registration website would not be regarded as a final submission, even if submitted as final.
Since this announcement was published, the formal opening of the registration website has occurred. Every registering FI must now revisit its account, edit information as needed, sign the foreign financial institution (FFI) agreement if registering as a participating FFI and submit registration information as final. The FI may also revoke its status by deleting its registration (if a GIIN has not been issued) or cancelling its registration (if a GIIN has been issued).
Final FFI Agreement
On December 26, 2013, the IRS and Treasury published Revenue Procedure 2014-13, which contained the FFI agreement. Corrections were made to the final FFI agreement on January 13, 2014 in sections 3.03(B)(1), 4.02(C), 5.01, 6.07, 9.02(B), 9.02(D) and 10.03 of section 5. For specifics, please review these sections in Revenue Procedure 2014-13.
Final qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) agreements will be published in early 2014. For additional details on QI, WP, or WT renewals, please refer to Announcement 2014-1.
All other dates relevant to registration and publication of the IRS FFI List as described in Notice 2013-43 remain unchanged. Please review Announcement 2014-1 for a recap of these dates as well.