We registered our trusts with HMRC for FACTA in 2014 and are now receiving emails from the IRS suggesting we renew the agreements. We fall under Model 1 IGA.
Have others received IRS emails and are we not covered by an HMRC/IRS agreement so can ignore the IRS renewal?
Guy Birtwistle
Fishers Dewes Solicitors
Ashby de la Zouch
We registered our trusts as well and have also been receiving the emails to say that a message has been posted.
The FATCA online registration guide (which can be downloaded from the IRS site) has a section on the renewal of the FATCA agreements. It says:
“Certain FIs and their branches must periodically renew their FFI agreement by verifying and updating their information. We will notify all approved FIs via email and message board when a required renewal period begins. We will also send a reminder message ten days prior to the due date.”
The table in the guide (and which comes up when you go through the renewal process) shows that an FI that is classified as a Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under Model 1 IGA) and that is a Reporting Model 1 FFI that is not operating branches outside of Model 1 jurisdictions do not need to renew the agreement.
However you do need to go through the process to confirm that for each FI before the end of July. The home page should then show the renewal status as not required – self determined.
The guide is here https://www.irs.gov/pub/irs-pdf/p5118.pdf
Nigel Scase
Greene & Greene
We also had similar. I completed the update in a matter of minutes. It enables any changes to be made, including who receives the emails for example - which had changed for us.
Lucy Orrow
Universal Wealth Preservation