The IRS has published Frequently Asked Questions regarding the FFI agreement renewal. The deadline for the renewal is July 31, 2017, and the obligation to renew applies to Participating FFIs not covered by an IGA, Reporting FFIs under a Model 2 IGA, and Registered Deemed-Compliant FFIs that are Reporting FFIs under a Model 1 IGA operating branches outside of Model 1 jurisdictions. The FAQs address a number of scenarios that FFIs may encounter in the registration and renewal process and provide details and instructions that are not covered within the registration publications.
About the Author
Tom Hospod is a member of the Tax Research Team for the Direct Tax division at Sovos Compliance, where his main areas of focus are Tax Withholding and Automatic Exchange of Information (AEOI). Prior to Sovos, Tom worked as a legislative aide in the Massachusetts House of Representatives. He also has experience in securities law—focusing on broker-dealer disputes and representing clients in FINRA arbitration. Tom is a member of the Massachusetts Bar, earned his B.A. from Boston College and his J.D. from the University of Miami.More Content by Tom Hospod