IEIM404520 - Reporting Format: FATCA Registration

Reporting Format: FATCA Registration

Each Reporting UK Financial Institution and any entity that is a Registered Deemed Compliant Entity or a Direct Reporting NFFE is required to register and obtain a Global Intermediary Identification Number (GIIN) from the IRS.

GIINs have been assigned to registered entities since January 2014. The IRS has published guidance regarding the registration process on the irs.gov website.

The following types of entity are not required to register and should not seek to do so:

• Non-Reporting UK Financial Institutions

• Deemed Compliant UK Financial Institutions (unless they are Registered Deemed Compliant)

• Active and Passive NFFEs (excluding Direct Reporting NFFEs).

Where a Financial Institution with a Local Client Base has a reporting obligation, because it has US Reportable Accounts, it will be required to obtain a GIIN.

Entities that are Reporting Financial Institutions and also acting as a sponsor for other entities will need to register separately for each of these roles.

An umbrella fund may register with the IRS either at sub-fund and/or umbrella level. This may lead to nil returns by the umbrella fund where the shares are issued to investors at sub-fund level however in this case all investors will be reported to HMRC at sub-fund level.