IRS Adds New Items to FAQs on FATCA IGAs

The IRS added two new items to the FATCA FAQs that are posted on its website. Both new items clarify issues with respect to Intergovernmental Agreements ("IGAs").

A new Question 7 was added to the FAQs section on IGA Registration and clarifies that a non-reporting financial entity in a Model 1 IGA jurisdiction generally is treated as a certified deemed-compliant financial institution and does not need to register with the IRS except in certain special circumstances, such as if it is acting as a sponsoring entity or as lead FFI for one or more related entities, or is explicitly required to register under the terms of the IGA. A new Question 8 was added to the FAQs section on General Compliance and explains in detail when and in what form self-certification may be made in accordance with Annex I of an IGA on a substitute Form W-8 or a "similar agreed form."

See: Updated FATCA IGA Registration FAQs; Updated FATCA General Compliance FAQs.
See also: FATCA Specialty Page (available to Cabinet subscribers only).

For more information, please contact Daniel Mulcahy or Mark Howe.