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PAI. For the requirements of a PAI

Entity that will perform the due diligence,

even though they are registered under two

contract, see the renewed 2014 Model QI

withholding, and reporting obligations on

different Lead FIs.

Agreement available at

its behalf.

Consolidated Compliance Program: If

an EAG has in place a consolidated

Qualified Intermediary (QI)

Sponsoring Entity

compliance program, as described in

Treas. Reg. §1.1471-4(f)(2)(ii), then

A Qualified Intermediary (QI) means an

A Sponsoring Entity means an entity that

Member FIs that elect to participate in the

FFI (or foreign branch of a USFI) that has

will perform the due diligence, withholding,

same consolidated compliance program

entered into a qualified intermediary

and reporting obligations of one or more

should be registered as Member FIs by

withholding agreement (QI Agreement)

sponsored investment entities or

the Lead FI that is acting as the

with the IRS.

controlled foreign corporations

Compliance FI for the compliance group.

(Sponsored FFIs).

Model 1 IGA (Select Registered

Registered Deemed

Deemed Compliant). FIs that are treated

United States

Compliant FFI (RDCFFI)

as Reporting FIs under a Model 1 IGA

United States means the United States of

A Registered Deemed Compliant FFI

(see the list of jurisdictions treated as

America, including the States thereof, but

(RDCFFI) means: (1) an FFI that is

having an IGA in effect at

does not include the U.S. Territories. Any

registering to confirm that it meets the

fatca) should register as RDCFFIs.

reference to a “State” of the United States

requirements to be treated as a local FFI,

A Reporting FI under a Model 1 IGA will

includes the District of Columbia.

nonreporting FI member of a PFFI group,

be able to register and obtain a GIIN prior

qualified collective investment vehicle,

to July 1, 2014, and may generally find it

U.S. Financial Institutions (USFI)

restricted fund, qualified credit card issuer,

convenient to do so. Nonetheless, such an

or sponsored investment entity or

FI is not required to provide a GIIN to

A U.S. Financial Institution (USFI) means

controlled foreign corporation (see Treas.

withholding agents prior to January 1,

an FI that is a resident of the United

Reg. §1.1471-5(f)(1)(i) for more

2015, and therefore has time beyond July

States.

information about these categories), (2) a

1, 2104, to register to obtain a GIIN. In

Reporting FI under a Model 1 IGA and that

addition, a Reporting FI under a Model 1

U.S. Territory

is registering to obtain a GIIN, or (3) an FFI

IGA must register prior to July 1, 2014, (1)

that is treated as a Nonreporting FI under

U.S. Territory means American Samoa,

if it maintains one or more branches (other

a Model 1 or 2 IGA and that is registering

the Commonwealth of the Northern

than a Limited Branch or U.S. branch) in

pursuant to the applicable Model 1 or 2

Mariana Islands, Guam, the

jurisdiction(s) that are not covered by a

IGA.

Commonwealth of Puerto Rico, or the U.S.

Model 1 IGA, (2) if it is renewing its QI,

Virgin Islands.

WP, or WT Agreement, or (3) if it intends

Reporting FI

to be a Lead FI for Member FIs that are

not established in, and operating

Withholding Foreign

A Reporting FI means an FI that is treated

exclusively in, other Model 1 IGA

Partnership (WP)

as a Reporting FI under the terms of a

jurisdictions.

Model 1 or Model 2 IGA that is in effect.

A Withholding Foreign Partnership (WP)

The term Reporting FI also includes a

Model 2 IGA (Select PFFI). FIs that are

means a foreign partnership that has

foreign branch of a USFI that is treated as

treated as Reporting FIs under a Model 2

entered into a withholding foreign

a Reporting FI under the terms of a Model

IGA (see the list of jurisdictions treated as

partnership agreement (WP Agreement)

1 IGA that is in effect. A foreign branch of

having an IGA in effect at

with the IRS.

a USFI treated as a Reporting FI under the

fatca) should register as PFFIs.

terms of a Model 2 IGA is not required to

FFIs that are also Sponsoring Entities.

Withholding Foreign Trust (WT)

submit a FATCA registration form to

An FFI that will also act as a Sponsoring

obtain a GIIN, unless it is renewing a QI

A Withholding Foreign Trust (WT) means

Entity for one or more Sponsored Entities

Agreement.

a foreign trust that has entered into a

is required to submit a second registration

withholding foreign trust agreement (WT

form to act as a Sponsoring Entity. The

Responsible Party

Agreement) with the IRS.

Sponsoring Entity will receive a separate

Sponsoring Entity GIIN and should only

A Responsible Party means the individual

Special Rules

use that GIIN when it is fulfilling its

responsible for the performance of the FI

obligations as a Sponsoring Entity.

under the terms of a QI, WP, or WT

Lead FI and Member FIs of an EAG. In

Agreement.

Instructions For Form 8957 - Foreign Account Tax Compliance Act (Fatca) Registration - 2013 Page 4

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