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ARTICLE · 09 JUNE 2014

I Have GIIN. Now What?

Herrick, Feinstein LLP
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By now, if you are a "foreign financial institution" for purposes of FATCA, you probably have registered with the IRS.

United StatesTax
Louis Tuchman
Louis Tuchman
Sung Hwang
Sung Hwang
Irwin Latner
Irwin Latner
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By now, if you are a "foreign financial institution" (FFI) for purposes of FATCA ("Foreign Account Tax Compliance Act"), you probably have registered with the IRS and are eagerly waiting your GIIN to be issued and for your name to be published in the first FFI List this week.

When you registered as an FFI on the IRS website, you should have been prompted to enter into an "FFI Agreement" with the IRS.  An FFI agreement provides the ground rules for an FFI to conduct KYC (know-your-customer) due diligence, report applicable information to the IRS, and withhold as required under FATCA. There is only one version of the FFI Agreement. If you are located in a Model 2 Inter-Governmental Agreement ("Model 2 IGA") jurisdiction, you are still entering into an FFI Agreement with the IRS, but the FFI Agreement ground rules are modified by the applicable Model 2 IGA.

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