The IRS today issued a transmittal message alerting foreign financial institutions (FFIs) that are required to renew their FFI agreements that they must review, update, and resubmit their registration application by 31 July 2017, in order to be treated as having in effect an FFI agreement as of 1 January 2017. Failure to renew may result in removal from the FFI list.
According to today’s IRS release, any FFI that entered into an FFI agreement before 2017 must renew its agreement to continue to be treated as a “Participating FFI” (including a Reporting Model 2 FFI). If the FFI does not renew its agreement (by entering into the current FFI agreement pursuant to Rev. Proc. 2017-16), the FFI will be considered a nonparticipating FFI as of 1 January 2017, and the FFI's GIIN will be removed from the FFI list. The IRS reported that if an FFI erroneously checked the box stating that it did not need to renew its FFI agreement, the FFI may return to the FATCA FFI Registration system home page and renew its FFI agreement before the 31 July deadline.
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