According to the IRS release [PDF 95 KB], financial institutions and host country tax authorities began IDES enrollment in January 2015. All IDES enrollees may use the IDES gateway to securely send Foreign Account Tax Compliance Act (FATCA) information reports on financial accounts held by U.S. persons.
The online address for IDES enrollment and a link to IDES gateway can be found on the IDES enrollment site, and the IDES user guide with instructions for enrolling and using IDES can be found on the IDES home page. To complete IDES enrollment, financial institutions will need to have registered as a participating financial institution through the IRS FATCA registration system and have a global intermediary identification number (GIIN) that appears on the current IRS FATCA FFI list.
The FFI list is issued by IRS and includes all financial institutions and branches that have submitted a registration and have been assigned a global intermediary identification number (GIIN) at the time the list was compiled.
Financial institutions and host country tax authorities are encouraged to complete the enrollment process and initiate transmission before the Form 8966 reporting deadline. An automatic 90-day extension of time to file Form 8966 may be requested. For calendar year 2014 only an automatic 90-day extension of time to file Form 8966 will be provided to all filers (including those filing electronically), without the need to file any form or take any action.
The IDES guidance focuses only on FFIs and specifically require a GIIN to register. However, only foreign FFIs have a GIIN. The IRS informally stated, that they would update guidance so that a U.S. FFI that is required to report certain payments on Form 8966 can register and report using its EIN. However, official guidance has not been released.
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