FATCA: UPDATED FAQS ON BRANCH REGISTRATION

The IRS today announced that it has updated the list of “frequently asked questions” (FAQs) concerning the FATCA regime. Specifically, the updated FAQs concern branch registration.

With today’s IRS release, the IRS explained that it has clarified questions concerning how does a branch in a Model 1 IGA or Model 2 IGA jurisdiction satisfy its FATCA registration requirements. The updated FAQs provide that, unless a specified exception applies, a branch must register as a branch of its owner and not as a separate entity. Also, new guidance has been added to instruct branches registered as separate entities as how to correct their registration.

The updated or new FAQs are indicated with the notation: “Added 8-25-15” in red font on the IRS FATCA webpage.