International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Thursday, November 26, 2015

IRS Upgrades and Enhances FATCA Registration System

The Internal Revenue Service has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, FATCA_rollenabling sponsoring entities to provide additional required details. The enhancements also aid users' ability to update their information, download registration tables and alter their financial institution type. The upgrade also includes an updated country/jurisdiction list.

FATCA requires sponsored entities (including those governed by an IGA) to have their own Global Intermediary Identification Number (GIIN) for FATCA reporting and withholding purposes by Dec. 31, 2016. To facilitate this requirement, the FATCA Online Registration System added features to enable sponsoring entities to add their sponsored entities and, if applicable, sponsored subsidiary branches. These can be added either individually or by submitting a file containing multiple records.

The IRS also provides a Microsoft Excel-based Sponsored Entity Data Preparation Tool for users choosing the multiple record file upload option. As a result of the new sponsored entities and sponsored subsidiary branches, the values available for the GIIN have expanded.  See the Instructions for Sponsored Entity Data Preparation Tool for XML File for the definitions of sponsored entities and sponsored subsidiary branches.

The update to the system occurred on November 16. The improvements to the system and additional features to manage user accounts include the following:  

• New questions have been added, such as asking foreign financial institutions to indicate their tax Identification number in their country or jurisdiction, if they have one. Other questions relate to identifying the common parent entity of the expanded affiliated group.

• Certain financial institutions can now change their “Financial Institution Type.”

• Member financial institutions can now transfer to another expanded affiliated group without having to cancel their current agreement and re-register.

Following the change or transfer, a new FATCA account will be created with existing registration information, including branches.  

The FATCA Online Registration System User Guide and FAQs have been updated for these enhancements. Additional information on this system is available at

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