The IRS updated its FATCA frequently asked questions and answers on July 23, providing new answers to the following questions:
1. When will the terms of the revised QI Agreement set forth in Revenue Procedure 2014-39 be effective for: (a) entities seeking QI status, and (b) entities seeking renewal of their QI Agreements?
2. Are U.S. Financial Institutions (USFIs) required to register under FATCA? If so, under what circumstances would a USFI register? Does it matter whether the USFI has a branch in an IGA jurisdiction?
3. What should a withholding agent do if an entity account holder indicates that box 9a of Form W–8BEN–E is too small to accommodate the entity’s GIIN?
