FATCA requires sponsored entities (including those governed by an IGA) to have their own Global Intermediary Identification Number (GIIN) for FATCA reporting and withholding purposes by 31 December, 2016. Under a transitional rule, it is possible for one FFI to act as a sponsor for a number of other FFIs. The sponsored FFI can then use the GIIN of the sponsoring FFI.

In order to facilitate enhanced reporting, the Internal Revenue Service has recently upgraded the FATCA Online Registration System and has added features to enable sponsoring entities to add the names of their

  • Sponsored entities, and
  • Sponsored subsidiary branches.

These can be added either individually or by submitting a file containing multiple records.

Additional improvements to the system and additional features to manage user accounts include the following.

Where applicable, FFIs may now

  • Indicate their tax identification number (TIN) in their country or jurisdiction.
  • Identify the common parent entity of an Expanded Affiliated Group (EAG) or transfer to another EAG without having to cancel their current agreement and re-register.
  • Change their Financial Institution Type.

Additional information on the above is available here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.