CRS and FATCA expert

Time to Renew the FFI Agreements

Peter Cotorceanu Blog, FATCA, FATCA Entity Classification

Upon registration for a GIIN via the IRS FATCA Registration Portal, certain FIs (i) subject to a Model 2 IGA, or (ii) not subject to any IGA automatically entered into a contract with the IRS known as the FFI Agreement. The FFI Agreement sets forth the FI’s rights and responsibilities (with responsibilities outnumbering rights heavily). In the scrum of FATCA …