The IRS announced on 2 April 2014, that the deadline for foreign financial institutions registering for a GIIN, in order to appear on the first issued IRS list of foreign financial institutions, has been pushed out from 25 April 2014 to 5 May 2014. They have also indicated that registrations finalised by 3 June 2014 will be included in the second IRS list issuing on 1 July 2014. Registrations that are finalised after 5 May or 3 June may still appear in the first or second IRS list respectively but this cannot be assured. While reporting financial institutions may want to register by 5 May 2014 to simplify the documentation of their status with withholding agents, withholding agents should not require Irish reporting financial institutions to provide a GIIN until 1 January 2015.
The US Internal Revenue Services released a final version of the form W-8BEN-E at the end of March. This is the principal form used in identifying non-US entities for FATCA and other US withholding tax purposes and incorporates the FATCA classifications that will be used by Irish entities to demonstrate to US withholding agents from which they receive US source income that they are resident for tax purposes in a Model 1 Intergovernmental Agreement country and their FATCA status.