On 26 December the IRS released an advance copy of Rev. Proc. 2014-10 providing text of an agreement for foreign financial institutions (FFIs) entering into an FFI agreement with the IRS, so that these FFIs can be treated as “participating FFIs.”
Rev. Proc. 2014-10 (PDF, 381 KB) provides:
The final FFI agreement contained in Rev. Proc. 2014-10 finalizes a draft FFI agreement (see our e-Alert 2013-26) and describes changes made to the draft FFI agreement.
Please note that the FFI agreement is not applicable to FFIs subject to Model 1 IGA.
Changes included in final FFI agreement
Among the changes made to the draft FFI agreement and finalized in the FFI agreement are measures that:
For further information, please do not hesitate to contact us.
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