Today the Internal Revenue Service issued Announcement 2014-1, entitled “Update on FATCA financial institution registration.” In the announcement, the IRS reminds foreign financial institutions (FFIs) that the online portal for FATCA registration has been open since August 19, 2013.
Announcement 2014-1 provides that all information entered by FFIs since August 19 has been automatically saved in the registration system and associated with the FFI’s FATCA account. With the exception of December 21 and December 31, 2013, when the registration website will undergo end-of-year processing, FFIs will continue to have access to the registration website to create accounts or access existing accounts to modify or add registration information.
The IRS previously notified FFIs (through Notice 2013-43) that any information entered in the registration system before January 1, 2014, even if submitted as “final,” would not be regarded as a final submission. As a result, all registrations prior to January 1, including registrations submitted as final before December 31, will be treated as “initiated but unsubmitted.” Thus, on or after January 1, 2014, every registering FFI must revisit its account, make edits to its information if necessary, sign its FFI agreement if registering as a participating FFI, and submit its registration information as final.
Announcement 2014-1 further provides that any FFI submitting its registration information on or after January 1 may subsequently choose to revoke its status by revisiting its account and deleting its registration (if its GIIN has not yet been issued) or cancelling its registration (if its GIIN has already been issued).
The IRS and Treasury anticipate that the final FFI agreement will be published prior to January 1, 2014 (a draft FFI agreement was previously published as part of Notice 2013-69; see prior coverage here).
Announcement 2014-1 concludes by confirming that all other dates relevant to registration and publication of the IRS FFI List as described in Notice 2013-43 remain unchanged. The IRS will electronically post the first IRS FFI List by June 2, 2014, and any FFI seeking to be included on the June 2014 IRS FFI List should finalize its registration by April 25, 2014.