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FATCA also requires such persons to self-report their non-U. financial assets annually to the Internal Revenue Service (IRS) on form 8938, which is in addition to the older and further redundant requirement to self-report them annually to the Financial Crimes Enforcement Network (Fin CEN) on form 114 (also known as 'FBAR'). FATCA is controversial because foreign banks have been forced to comply under threat of a 30% withholding penalty on all their U. Does a QI have reason to know that a Form W-8 provided by a direct account holder to establish foreign status is unreliable or incorrect if the QI has, as part of its account information, a current residence or mailing address that is an address in the United States? If a direct account holder of a QI claiming treaty benefits provides documentary evidence to establish residence in a jurisdiction with an income tax treaty, what additional documentation can the QI rely on for purposes of treating the documentation as valid under section 5.10(B) of the 2017 QI agreement when the QI has reason to know that the documentary evidence provided is unreliable or incorrect? What is the status of the approved know-your-customer (KYC) attachments to the 2017 QI, WP, and WT agreements for purposes of the documentation requirements of a QI, WP, or WT that is an FFI? Must an FI become a QI/WP/WT in order to register under FATCA? If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer? If a member of the Expanded Affiliated Group is a Qualified Intermediary/Withholding Trust/Withholding Partnership, does the Lead Financial Institution renew the Qualified Intermediary/Withholding Trust/Withholding Partnership agreement on behalf of the member or does the member renew its own agreement? If a prospective QI has a branch that is a prospective QDD, the branch may apply for QDD status even if the prospective QI (apart from such branch) is not an eligible entity. In a Model 1 IGA jurisdiction, does the FFI need to fill out Question 10 about Responsible Officers? Does an FFI in a Model 1 IGA jurisdiction need to register before July 1, 2014, if the FFI is part of an EAG? Does an entity in a Model 1 jurisdiction that, relying on the definition of a nonreporting financial institution under the applicable IGA, qualifies as a deemed-compliant FFI or an exempt beneficial owner under relevant U. Treasury Regulations, need to register on the FATCA registration website? Announcement 2014-38 provides that a jurisdiction that is treated as if it has an IGA in effect, but that has not yet signed an IGA, retains such status beyond December 31, 2014, provided that the jurisdiction continues to demonstrate firm resolve to sign the IGA that was agreed in substance. Does it matter whether the USFI has a branch in an IGA jurisdiction? Is a Foreign Financial Institution (“FFI”) required to obtain an EIN? How does a FFI apply for a EIN if it does not already have one? Is the entity eligible to register and receive a GIIN? What is the Office of Foreign Asset Control's Specially Designated Nationals (SDN) list? I am an entity that is registered on the FATCA registration system and that has been issued a GIIN. The “Renew FFI Agreement” link asks if I and/or my branches are required to renew the FFI agreement. What happens if I do not select either “Yes” or “No”? Under prior guidance applicable to QIs, a QI was permitted to rely on a claim for treaty benefits in those cases by obtaining certain additional documentation without referencing whether the QI had a permanent residence address for the account holder in the jurisdiction for which treaty benefits were claimed. Each prospective QDD must separately qualify, apply, and be approved for QDD status, including meeting the eligible entity requirements as if it were a separate entity. Can a Member FI complete its FATCA registration and obtain a GIIN if the Lead FI for that Member FI has not yet registered under FATCA? Is a limited FFI who is a member of an Expanded Affiliated Group subject to Chapter 4 withholding? We are a Sponsoring Entity, and we would like to register our Sponsored Entities. Participating Foreign Financial Institution “PFFI”, PFFI that elects to be part of a consolidated compliance program, Registered Deemed-Compliant Foreign Financial Institution “RDCFFI”, Reporting Model 1 FFI, Limited FFI and US Financial Institution “USFI”) what type of individual may serve as a Responsible Officer for purposes of Part 1, Question 10 of the FATCA Registration? Additional questions related to: Part 4 of the online registration system* Q1. If so, under what circumstances would a USFI register? Will we be subject to FATCA withholding if we do not register? What should I do to return to approved status on the FATCA FFI List? Why did my registration status change to Registration Incomplete? Participating Foreign Financial Institution “PFFI” for Reporting Model 2 FFI, Registered Deemed Compliant Foreign Financial Institutions “RDCFFI” (for both Model 1 and non-Model 1 FFIs), Sponsoring Entity, Limited FFI or Limited Branch, Renewing QI/WP/WT, US Financial Institution “USFI” treated as a Lead FI and Direct Reporting NFFE) what is the impact of completing Part IV of the FATCA Registration? How do Trustees of Trustee-Documented Trusts register? Does an FFI registering to become a PFFI (including a reporting Model 2 FFI) need to complete a paper version of the FFI Agreement? What action should a FATCA registrant take if it improperly completes multiple FATCA registrations? The entity I represent is on the Office of Foreign Asset Control's Specially Designated Nationals list. I have determined based on the chart above that I am not required to renew an FFI agreement. What happens if I am an entity that entered into the FFI agreement contained in Revenue Procedure 2014-38 before January 1, 2017, but I do not renew my FFI agreement by July 31, 2017? Can I still renew the FFI agreement and be treated as having the current FFI agreement in effect as of January 1, 2017? What are the most common errors made during the registration process? Section 1.1441-7(b)(3) cross-references §1.1441-7(b)(9)(i) for the validity requirements for a treaty claim supported by documentary evidence, which provides that documentary evidence is unreliable or incorrect if the withholding agent has a current mailing or current permanent residence address for the direct account holder (whether or not on the documentary evidence) that is outside the applicable treaty country, or when the withholding agent has no permanent residence address for the account holder, a requirement that was also included in the 2014 QI agreement.What information should be provided for question 20 of Part 1? Description of new account opening procedures (If the Applicant is a WP or WT, provide a description of the procedures for admitting a new partner, beneficiary, or owner) (If the applicant is applying for QDD or QSL status, describe the Applicant’s procedures for collecting documentation from counterparties)Q7. How does an applicant provide the description of the types of transactions for applications submitted in 2017? How does an applicant provide the approximate value of transactions by account holder type for applications submitted in 2017? What information must an applicant provide when describing why it is an eligible entity? What information is necessary to describe how an applicant determines which transactions are included of its QDD business? When submitting an application in 2017, should the applicant address non-delta one transactions when completing section 3? An FI is not required to obtain QI/WP or WT status to register under FATCA.My application for renewal of QI/WP/WT status was not approved and was placed into incomplete status due to compliance issues. If at the time of FATCA registration, the FI does not have in effect a withholding agreement with the IRS to be treated as a QI, WP or WT, the FI will indicate “Not applicable” in box 6 and will continue with the registration process. If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer? While a boon for the financial consultancy and IT industry, it is an extra cost that institutions would rather not have." citing its multiple breaches of constitutional rights, double standard of compliance (non-US banks have been forced to comply but US banks have not), and its enforcement of differential treatment for US citizens depending on where they live, with non-residents granted fewer protections whilst being expected to comply with much more burdensome requirements. expatriates, many citing specific consequences of FATCA in their countries of residence, and nearly all calling both for residence-based taxation and the repeal of FATCA. The United States Department of the Treasury has published model IGAs which follow two approaches. For this reason, the increased reporting requirements of FATCA have had extensive implications for U. Industry members estimated increase of cost per account around USD 20-50." "FATCA requires major initial investment within an institution, estimated at ,000 for smaller institutions, to 0,000 to 0,000 for most institutions and

FATCA also requires such persons to self-report their non-U. financial assets annually to the Internal Revenue Service (IRS) on form 8938, which is in addition to the older and further redundant requirement to self-report them annually to the Financial Crimes Enforcement Network (Fin CEN) on form 114 (also known as 'FBAR'). FATCA is controversial because foreign banks have been forced to comply under threat of a 30% withholding penalty on all their U. Does a QI have reason to know that a Form W-8 provided by a direct account holder to establish foreign status is unreliable or incorrect if the QI has, as part of its account information, a current residence or mailing address that is an address in the United States? If a direct account holder of a QI claiming treaty benefits provides documentary evidence to establish residence in a jurisdiction with an income tax treaty, what additional documentation can the QI rely on for purposes of treating the documentation as valid under section 5.10(B) of the 2017 QI agreement when the QI has reason to know that the documentary evidence provided is unreliable or incorrect? What is the status of the approved know-your-customer (KYC) attachments to the 2017 QI, WP, and WT agreements for purposes of the documentation requirements of a QI, WP, or WT that is an FFI? Must an FI become a QI/WP/WT in order to register under FATCA? If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer? If a member of the Expanded Affiliated Group is a Qualified Intermediary/Withholding Trust/Withholding Partnership, does the Lead Financial Institution renew the Qualified Intermediary/Withholding Trust/Withholding Partnership agreement on behalf of the member or does the member renew its own agreement? If a prospective QI has a branch that is a prospective QDD, the branch may apply for QDD status even if the prospective QI (apart from such branch) is not an eligible entity. In a Model 1 IGA jurisdiction, does the FFI need to fill out Question 10 about Responsible Officers? Does an FFI in a Model 1 IGA jurisdiction need to register before July 1, 2014, if the FFI is part of an EAG? Does an entity in a Model 1 jurisdiction that, relying on the definition of a nonreporting financial institution under the applicable IGA, qualifies as a deemed-compliant FFI or an exempt beneficial owner under relevant U. Treasury Regulations, need to register on the FATCA registration website? Announcement 2014-38 provides that a jurisdiction that is treated as if it has an IGA in effect, but that has not yet signed an IGA, retains such status beyond December 31, 2014, provided that the jurisdiction continues to demonstrate firm resolve to sign the IGA that was agreed in substance. Does it matter whether the USFI has a branch in an IGA jurisdiction? Is a Foreign Financial Institution (“FFI”) required to obtain an EIN? How does a FFI apply for a EIN if it does not already have one? Is the entity eligible to register and receive a GIIN? What is the Office of Foreign Asset Control's Specially Designated Nationals (SDN) list? I am an entity that is registered on the FATCA registration system and that has been issued a GIIN. The “Renew FFI Agreement” link asks if I and/or my branches are required to renew the FFI agreement. What happens if I do not select either “Yes” or “No”? Under prior guidance applicable to QIs, a QI was permitted to rely on a claim for treaty benefits in those cases by obtaining certain additional documentation without referencing whether the QI had a permanent residence address for the account holder in the jurisdiction for which treaty benefits were claimed. Each prospective QDD must separately qualify, apply, and be approved for QDD status, including meeting the eligible entity requirements as if it were a separate entity. Can a Member FI complete its FATCA registration and obtain a GIIN if the Lead FI for that Member FI has not yet registered under FATCA? Is a limited FFI who is a member of an Expanded Affiliated Group subject to Chapter 4 withholding? We are a Sponsoring Entity, and we would like to register our Sponsored Entities. Participating Foreign Financial Institution “PFFI”, PFFI that elects to be part of a consolidated compliance program, Registered Deemed-Compliant Foreign Financial Institution “RDCFFI”, Reporting Model 1 FFI, Limited FFI and US Financial Institution “USFI”) what type of individual may serve as a Responsible Officer for purposes of Part 1, Question 10 of the FATCA Registration? Additional questions related to: Part 4 of the online registration system* Q1. If so, under what circumstances would a USFI register? Will we be subject to FATCA withholding if we do not register? What should I do to return to approved status on the FATCA FFI List? Why did my registration status change to Registration Incomplete? Participating Foreign Financial Institution “PFFI” for Reporting Model 2 FFI, Registered Deemed Compliant Foreign Financial Institutions “RDCFFI” (for both Model 1 and non-Model 1 FFIs), Sponsoring Entity, Limited FFI or Limited Branch, Renewing QI/WP/WT, US Financial Institution “USFI” treated as a Lead FI and Direct Reporting NFFE) what is the impact of completing Part IV of the FATCA Registration? How do Trustees of Trustee-Documented Trusts register? Does an FFI registering to become a PFFI (including a reporting Model 2 FFI) need to complete a paper version of the FFI Agreement? What action should a FATCA registrant take if it improperly completes multiple FATCA registrations? The entity I represent is on the Office of Foreign Asset Control's Specially Designated Nationals list. I have determined based on the chart above that I am not required to renew an FFI agreement. What happens if I am an entity that entered into the FFI agreement contained in Revenue Procedure 2014-38 before January 1, 2017, but I do not renew my FFI agreement by July 31, 2017? Can I still renew the FFI agreement and be treated as having the current FFI agreement in effect as of January 1, 2017? What are the most common errors made during the registration process? Section 1.1441-7(b)(3) cross-references §1.1441-7(b)(9)(i) for the validity requirements for a treaty claim supported by documentary evidence, which provides that documentary evidence is unreliable or incorrect if the withholding agent has a current mailing or current permanent residence address for the direct account holder (whether or not on the documentary evidence) that is outside the applicable treaty country, or when the withholding agent has no permanent residence address for the account holder, a requirement that was also included in the 2014 QI agreement.What information should be provided for question 20 of Part 1? Description of new account opening procedures (If the Applicant is a WP or WT, provide a description of the procedures for admitting a new partner, beneficiary, or owner) (If the applicant is applying for QDD or QSL status, describe the Applicant’s procedures for collecting documentation from counterparties)Q7. How does an applicant provide the description of the types of transactions for applications submitted in 2017? How does an applicant provide the approximate value of transactions by account holder type for applications submitted in 2017? What information must an applicant provide when describing why it is an eligible entity? What information is necessary to describe how an applicant determines which transactions are included of its QDD business? When submitting an application in 2017, should the applicant address non-delta one transactions when completing section 3? An FI is not required to obtain QI/WP or WT status to register under FATCA.My application for renewal of QI/WP/WT status was not approved and was placed into incomplete status due to compliance issues. If at the time of FATCA registration, the FI does not have in effect a withholding agreement with the IRS to be treated as a QI, WP or WT, the FI will indicate “Not applicable” in box 6 and will continue with the registration process. If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer? While a boon for the financial consultancy and IT industry, it is an extra cost that institutions would rather not have." citing its multiple breaches of constitutional rights, double standard of compliance (non-US banks have been forced to comply but US banks have not), and its enforcement of differential treatment for US citizens depending on where they live, with non-residents granted fewer protections whilst being expected to comply with much more burdensome requirements. expatriates, many citing specific consequences of FATCA in their countries of residence, and nearly all calling both for residence-based taxation and the repeal of FATCA. The United States Department of the Treasury has published model IGAs which follow two approaches. For this reason, the increased reporting requirements of FATCA have had extensive implications for U. Industry members estimated increase of cost per account around USD 20-50." "FATCA requires major initial investment within an institution, estimated at $25,000 for smaller institutions, to $100,000 to $500,000 for most institutions and $1 million for larger firms. § 1298(f) requiring shareholders of a passive foreign investment company (PFIC) to report certain information. With the IGA's, the private data of suspected US persons would be collected and handled by the FFI's, whereas the many governments would then collect and store that data for further transmittal.

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FATCA also requires such persons to self-report their non-U. financial assets annually to the Internal Revenue Service (IRS) on form 8938, which is in addition to the older and further redundant requirement to self-report them annually to the Financial Crimes Enforcement Network (Fin CEN) on form 114 (also known as 'FBAR').

FATCA is controversial because foreign banks have been forced to comply under threat of a 30% withholding penalty on all their U.

Does a QI have reason to know that a Form W-8 provided by a direct account holder to establish foreign status is unreliable or incorrect if the QI has, as part of its account information, a current residence or mailing address that is an address in the United States? If a direct account holder of a QI claiming treaty benefits provides documentary evidence to establish residence in a jurisdiction with an income tax treaty, what additional documentation can the QI rely on for purposes of treating the documentation as valid under section 5.10(B) of the 2017 QI agreement when the QI has reason to know that the documentary evidence provided is unreliable or incorrect? What is the status of the approved know-your-customer (KYC) attachments to the 2017 QI, WP, and WT agreements for purposes of the documentation requirements of a QI, WP, or WT that is an FFI? Must an FI become a QI/WP/WT in order to register under FATCA? If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer? If a member of the Expanded Affiliated Group is a Qualified Intermediary/Withholding Trust/Withholding Partnership, does the Lead Financial Institution renew the Qualified Intermediary/Withholding Trust/Withholding Partnership agreement on behalf of the member or does the member renew its own agreement? If a prospective QI has a branch that is a prospective QDD, the branch may apply for QDD status even if the prospective QI (apart from such branch) is not an eligible entity. In a Model 1 IGA jurisdiction, does the FFI need to fill out Question 10 about Responsible Officers? Does an FFI in a Model 1 IGA jurisdiction need to register before July 1, 2014, if the FFI is part of an EAG? Does an entity in a Model 1 jurisdiction that, relying on the definition of a nonreporting financial institution under the applicable IGA, qualifies as a deemed-compliant FFI or an exempt beneficial owner under relevant U. Treasury Regulations, need to register on the FATCA registration website? Announcement 2014-38 provides that a jurisdiction that is treated as if it has an IGA in effect, but that has not yet signed an IGA, retains such status beyond December 31, 2014, provided that the jurisdiction continues to demonstrate firm resolve to sign the IGA that was agreed in substance. Does it matter whether the USFI has a branch in an IGA jurisdiction? Is a Foreign Financial Institution (“FFI”) required to obtain an EIN? How does a FFI apply for a EIN if it does not already have one? Is the entity eligible to register and receive a GIIN? What is the Office of Foreign Asset Control's Specially Designated Nationals (SDN) list? I am an entity that is registered on the FATCA registration system and that has been issued a GIIN. The “Renew FFI Agreement” link asks if I and/or my branches are required to renew the FFI agreement. What happens if I do not select either “Yes” or “No”? Under prior guidance applicable to QIs, a QI was permitted to rely on a claim for treaty benefits in those cases by obtaining certain additional documentation without referencing whether the QI had a permanent residence address for the account holder in the jurisdiction for which treaty benefits were claimed.

Each prospective QDD must separately qualify, apply, and be approved for QDD status, including meeting the eligible entity requirements as if it were a separate entity. Can a Member FI complete its FATCA registration and obtain a GIIN if the Lead FI for that Member FI has not yet registered under FATCA? Is a limited FFI who is a member of an Expanded Affiliated Group subject to Chapter 4 withholding? We are a Sponsoring Entity, and we would like to register our Sponsored Entities. Participating Foreign Financial Institution “PFFI”, PFFI that elects to be part of a consolidated compliance program, Registered Deemed-Compliant Foreign Financial Institution “RDCFFI”, Reporting Model 1 FFI, Limited FFI and US Financial Institution “USFI”) what type of individual may serve as a Responsible Officer for purposes of Part 1, Question 10 of the FATCA Registration? Additional questions related to: Part 4 of the online registration system* Q1. If so, under what circumstances would a USFI register? Will we be subject to FATCA withholding if we do not register? What should I do to return to approved status on the FATCA FFI List? Why did my registration status change to Registration Incomplete? Participating Foreign Financial Institution “PFFI” for Reporting Model 2 FFI, Registered Deemed Compliant Foreign Financial Institutions “RDCFFI” (for both Model 1 and non-Model 1 FFIs), Sponsoring Entity, Limited FFI or Limited Branch, Renewing QI/WP/WT, US Financial Institution “USFI” treated as a Lead FI and Direct Reporting NFFE) what is the impact of completing Part IV of the FATCA Registration? How do Trustees of Trustee-Documented Trusts register? Does an FFI registering to become a PFFI (including a reporting Model 2 FFI) need to complete a paper version of the FFI Agreement? What action should a FATCA registrant take if it improperly completes multiple FATCA registrations? The entity I represent is on the Office of Foreign Asset Control's Specially Designated Nationals list. I have determined based on the chart above that I am not required to renew an FFI agreement. What happens if I am an entity that entered into the FFI agreement contained in Revenue Procedure 2014-38 before January 1, 2017, but I do not renew my FFI agreement by July 31, 2017? Can I still renew the FFI agreement and be treated as having the current FFI agreement in effect as of January 1, 2017? What are the most common errors made during the registration process? Section 1.1441-7(b)(3) cross-references §1.1441-7(b)(9)(i) for the validity requirements for a treaty claim supported by documentary evidence, which provides that documentary evidence is unreliable or incorrect if the withholding agent has a current mailing or current permanent residence address for the direct account holder (whether or not on the documentary evidence) that is outside the applicable treaty country, or when the withholding agent has no permanent residence address for the account holder, a requirement that was also included in the 2014 QI agreement.

What information should be provided for question 20 of Part 1? Description of new account opening procedures (If the Applicant is a WP or WT, provide a description of the procedures for admitting a new partner, beneficiary, or owner) (If the applicant is applying for QDD or QSL status, describe the Applicant’s procedures for collecting documentation from counterparties)Q7. How does an applicant provide the description of the types of transactions for applications submitted in 2017? How does an applicant provide the approximate value of transactions by account holder type for applications submitted in 2017? What information must an applicant provide when describing why it is an eligible entity? What information is necessary to describe how an applicant determines which transactions are included of its QDD business? When submitting an application in 2017, should the applicant address non-delta one transactions when completing section 3? An FI is not required to obtain QI/WP or WT status to register under FATCA.

My application for renewal of QI/WP/WT status was not approved and was placed into incomplete status due to compliance issues. If at the time of FATCA registration, the FI does not have in effect a withholding agreement with the IRS to be treated as a QI, WP or WT, the FI will indicate “Not applicable” in box 6 and will continue with the registration process. If an FFI has a QI/WP/WT agreement in place, does the Responsible Party for purposes of the QI/WP/WT Agreement also have to the serve as the FFI’s Responsible Officer?

million for larger firms. § 1298(f) requiring shareholders of a passive foreign investment company (PFIC) to report certain information. With the IGA's, the private data of suspected US persons would be collected and handled by the FFI's, whereas the many governments would then collect and store that data for further transmittal.

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persons for tax purposes" and to collect and store information including total asset value and Social Security number. FATCA is used by government personnel to detect indicia of U. persons and their assets and to enable cross-checking where assets have been self-reported by individuals to the IRS or to the Financial Crimes Enforcement Network (Fin CEN). Such a ruling would therefore be a finding of unconstitutionality as a matter of Canadian constitutional law, as to the two litigants. This complaint is suggestive that such taxation violates the IRS Taxpayer Bill of Rights provision #10 "The Right to a Fair and Just Tax System." On October 7, 2014, the legal claim by the Alliance for the Defence of Canadian Sovereignty was amended to include the allegation that the FATCA IGA and enabling legislation are in violation of both the Income Tax Act of Canada and the Canada U. The Common Reporting Standard requires each signatory country to gather the full identifying information of each bank customer, including additional nationalities and place of birth. In the law, financial institutions would report the information they gather to the U. CRS is capable of transmitting person data according to the demands of either Residence Based Taxation or Citizenship Based Taxation (CBT) or Personhood-Based Taxation.