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The next step for all Irish entities which are classified as Financial Institutions ("FIs") for FATCA purposes is to submit a return (the "FATCA Return") to Irish Revenue setting out details of any US reportable accounts they may have maintained during the 2014 calendar year, or to confirm by way of nil return that they maintained no such accounts.

In a fast-paced business world, with constantly evolving group operational structures and trading relationships, how long does an arrangement really remain unchanged?