By Karen Wallace, Global Head of Compliance Apex Fund Services
The IRS on-line 
registration portal went ‘live’ on 1 January this year and Foreign Financial Institutions (“FFIs”) should now be preparing to register with the IRS to obtain a Global Intermediary Identification Number (“GIIN”). FFIs must register with the IRS to obtain a GIIN by the 25th April 2014 in order to ensure inclusion on the list of compliant FFIs on the 2nd June 2014. The FFI list will be updated monthly following the publication of the June 2014 list.
For further information on the registration process click here
The IRS signed Intergovernmental Agreements (“IGAs”) with two key off-shore jurisdictions late last year. The IRS entered into a Model 1 IGA with the Cayman Islands and a Model 2 IGA with Bermuda. The key difference between a Model 1 and Model 2 IGA is that under a Model 2 agreement FFIs are required to report specified information about US account holders directly to the IRS rather than indirectly through the local authorities. FFIs that do not comply with the requirements of a local IGA will be in violation of local law and subject to enforcement action/penalties by local governments.
Click here to review jurisdictions that are treated as having an intergovernmental agreement in effect.
The timeframe for implementation of your fund’s FATCA obligations requires immediate attention as the deadline of 30th June 2014 is fast approaching. Apex Fund Services is offering FATCA solutions to our clients.
For further information: Karen Wallace Tel: +353 21 463 3366 E-mail: karen@apexfunds.ie