The IRS today issued a release updating a list of “frequently asked questions” (FAQs) concerning foreign financial institution (FFI) agreement renewal and specifically concerning entities that missed the July 31, 2017 renewal deadline.
As noted in today’s IRS transmittal message, the updated FAQ answers the following question:
I am an entity that must renew the FFI agreement, but I missed the July 31, 2017, renewal deadline. Can I still renew the FFI agreement and be treated as having the current FFI agreement in effect as of January 1, 2017?
Yes, participating FFIs (including Reporting Model 2 FFIs) that have otherwise complied with the terms of the FFI agreement (including, since January 1, 2017, the current FFI Agreement) have until October 24, 2017, to renew the FFI agreement and continue to be treated as a participating FFI.
If an entity that is required to renew the FFI agreement does not renew the FFI agreement by October 24, 2017, the registration status of the entity will be changed to “incomplete,” the entity’s GIIN will no longer appear on the monthly FFI List beginning in November, and the entity will be considered a nonparticipating FFI as of January 1, 2017, as provided in section 3.02 of Revenue Procedure 2017-16.
The new FAQ has a notation: “Added: 08-01-2017”
The new FAQ can be found in the registration update section on the “FATCA-FAQs General” webpage under the “Registration Update” header.
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