IRS releases long-awaited draft FFI agreement and previews updates to FATCA regulations

By Michael J Legamaro, Witold Jurewicz and Michael Greenberg

The Internal Revenue Service (IRS) has released Notice 2013-69, including a draft FFI agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA).

The draft FFI agreement outlines the obligations of foreign financial institutions (FFIs) that will register with the IRS to become participating FFIs (PFFIs) under FATCA.

FFIs and their branches located in countries that have entered into a Model 2 intergovernmental agreement (IGA) with the US (Model 2 FFIs) will also be required to agree to comply with the terms of an FFI agreement, as modified by the terms of the applicable Model 2 IGA. PFFIs and Model 2 FFIs will avoid the new 30 per cent FATCA withholding tax on US source payments made to FFIs, beginning 1 July 2014…

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