The FATCA Registration Process -- A Primer on the IRS FFI Net

Dean Marsan

Charles Schwab and Co., Inc.

September 16, 2013

Tax Notes, Vol. 140, No. 12, pages 1209-1329

In this report, Dean Marsan examines the new foreign financial institution registration process created by the IRS and how it will fit into the larger FATCA and tax information global ecosystem. After conducting an in-depth review of the registration process contemplated by the IRS for global financial institutions — small and large, foreign and U.S. — Marsan concludes that the newly finalized Form 8957, "Foreign Account Tax Compliance Act (FATCA) Registration," and its electronic brethren on the newly opened FATCA portal funnel into a single registration form more than 700 pages of tax regulations and other administrative guidance, hundreds of pages of newly (and yet to be agreed on) intergovernmental agreements from more than 80 countries, and the domestic laws in each of those countries. This report includes a discussion of the FATCA online registration user guide recently released by the IRS, and the correcting amendments to the FATCA final regulations released on September 10, including current registration planning under those new rules.

Number of Pages in PDF File: 118

Keywords: FATCA registration, FATCA, FFI, IGA, GIIN, Lead FFI, Sponsored FFI, FATCA ID, EAG, Form 8957, tax information reporting, PFFI, Limited FFI, Branch, USFI, QI, NQI, Member, RO, POC, USWA, TIN, NFFE, ECI, FDAP

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Date posted: October 31, 2013  

Suggested Citation

Marsan, Dean, The FATCA Registration Process -- A Primer on the IRS FFI Net (September 16, 2013). Tax Notes, Vol. 140, No. 12, pages 1209-1329. Available at SSRN: https://ssrn.com/abstract=2347551

Contact Information

Dean Marsan (Contact Author)
Charles Schwab and Co., Inc. ( email )
United States
917.669.9422 (Phone)
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