Foreign Financial Institutions Can Now Complete FATCA Registration Online

Under the Foreign Account Tax Compliance Act ("FATCA"), foreign financial institutions ("FFIs") may avoid withholding tax that will otherwise be imposed on U.S.-source payments made on after July 1, 2014, by registering with the IRS and agreeing to report to the IRS certain information about their U.S. accounts, including accounts of certain foreign entities with substantial U.S. owners. FFIs that qualify for an exemption from the FATCA reporting requirements (including FFIs resident in a country that enters into an intergovernmental agreement with the IRS) are generally required to register as well. The IRS has established the "FATCA Registration Website" to allow FFIs to register and, upon approval, receive a Global Intermediary Identification Number ("GIIN") from the IRS online. The IRS will publish a list of registered and approved FFIs and their GIINs every month, so that withholding agents will be aware that withholding is not required on these FFIs. The FATCA