On 22 March 2019, the U.S. Internal Revenue Service (“IRS”) updated its Frequently Asked Questions (“FAQs”) on Qualified Intermediaries (“QI”), Withholding Foreign Partnerships (“WP”) and Withholding Foreign Trusts (“WT”) (Link). Question 17 in the section “Registration Update” has been updated to support users in understanding the respective requirements:
- Question 17: Why has my FATCA Registration account been placed in “Registration Rejected/Denied” status?
- Answer 17: Accounts that have been in either 1) “Initiated” 2) “Registration Incomplete” or 3) “Under Review” status for six months or more are deemed inactive and will be placed in “Registration Rejected/Denied” status. When an account is placed in this status you still have access to your message board; however, you will not have any other available account options. If you need a GIIN and meet the criteria, complete and submit a new FATCA Registration.
Question 19 in the section “FATCA Certifications” has also been updated:
- Question 19: How does a Sponsoring Entity complete and submit a certification for its Sponsored Entity(s) which were closed/terminated and are not reflected in the Sponsored Entity table for selection?
- Answer 19: We are aware that the system does not currently display any closed/terminated Sponsored Entities in the Sponsored Entity table for selection. Until further notice, Sponsors should both: (1) use the business description text box to include the name(s) and GIIN(s) of closed/terminated sponsored entities that are being included in the certification; and (2) maintain as part of their records a list of the closed/terminated sponsored entities included in the certification, which the Sponsor may be required to provide to the IRS upon request. If the space provided in the business description text box is not enough to include all of the closed/terminated Sponsored Entities for which the certification applies, Sponsors should include a notation in that text box indicating that additional entities not listed are part of the certification and that a list of all Sponsored Entities (including the names and GIINs) will be provided to the IRS when requested.