On August 8, 2016, the IRS updated the “frequently asked questions” (FAQs) on the FATCA IDES Technical FAQs section at IRS.gov.
IDES stands for the “International Data Exchange Services” system that allows the IRS to exchange taxpayer information with foreign tax authorities. While the FAQs are focused primarily on technical issues, such as data preparation, testing and security, several of the revisions provide guidance on substantive FATCA reporting issues.
New Q:A18 clarifies that reports made by “Direct Reporting Non-Financial Foreign Entities” (NFFE) located in Model One IGA jurisdictions are to be made directly to the IRS rather than through their Host Country Tax Authority (HCTA). Generally when using IDES, files uploaded by a foreign financial institution (FFI) in a “M1O2” jurisdiction will be routed to the HCTA. The FAQ provides that “when a Direct Reporting NFFE applies for its Global Intermediary Identification Number(GIIN) through the FATCA Online Registration portal it
