With 89 days until many of the provisions of FATCA take effect, a number of FFIs resident or organized in 20 different jurisdictions have been provided temporary IGA FFI status until December 31, 2014.
With 89 days until many of the provisions of FATCA (Foreign Account Tax Compliance Act) take effect, a number of foreign financial institutions (FFIs) resident or organized in 20 different jurisdictions have been provided temporary intergovernmental agreement (IGA) FFI status until December 31, 2014. This ‘in effect’ status is the basis for determining the requirements for FFIs in these jurisdictions regarding IRS registration and the potential due diligence, withholding, and reporting obligations under FATCA. The ‘in effect’ status only applies to an institution resident in such country, but does not include branches located outside of such country. It also applies to any branch located in the IGA country.
This temporary status was provided in Announcement 2014-17 released on April 2, 2014 by the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS). The announcement, which was accompanied by a separate Treasury press release, provides two significant changes: