Treasury Publishes First FATCA FFI List

The IRS and the U.S. Treasury Department ("Treasury") published the initial list of foreign financial institutions ("FFIs") that registered with the IRS and were issued a Global Intermediary Identification Number ("GIIN").FFIs are required to provide their GIIN to U.S. and non-U.S. withholding agents and such withholding agents are required to check the FFI list to verify the foreign entity's GIIN. The FFI list contains over 77,000 financial institutions initially and will be updated on the first of every month. The IRS announced that FFIs that have not yet registered with the IRS have until May 23, 2014, to register to be on the FFI list that will be issued on July 1, the date that withholding under FATCA begins. FFIs that are located in countries with a Model 1 Intergovernmental Agreement ("IGA") are not required to have a GIIN until January 1, 2015, and can register with the IRS as late as December 23, 2014 and still receive a GIIN by year-end. However, many FFIs in Model 1 countries have already registered. For example, over 14,000 FFIs in the Cayman Islands, a Model 1 country, have registered.

The FFI list is available on the IRS website linked below. It can be downloaded in full or searched by country, name of the FFI or GIIN.

See: List of FFIs by Jurisdiction.See also: Cabinet FATCA Materials (for Cabinet subscribers only). For more information, please contact Daniel Mulcahy and Mark Howe.