IRS Amends FATCA FAQs Again

On May 1, 2014, the IRS added four new questions and answers to its FATCA FAQs Web site. Two of the new questions and answers address who may act as Responsible Officer for a Foreign Financial Institution ("FFI") and the scope of the certification that such Responsible Officer is required to make in connection with the registration of the FFI with the IRS, in each case depending on the status of the particular FFI under FATCA. Another FAQ discusses the impact of completing Part IV of the Registration, which again differs depending on the status of the FFI that is being registered. The last two FAQs that were added deal with registering disregarded entities and branches located in Model 1 IGA countries and those that are located in non-IGA countries or in Model 2 IGA countries.

May 5, 2014 is the last day on which an FFI may register and be assured that it is on the FFI List issued by the IRS on June 2, 2014.

See: IRS Revised FAQs.