! or RDCFFI that is not required to file Form 8966

CAUTION may still be required to report a payment under

chapter 61.

Form 8966 is not used to report any tax withheld

TIP under chapter 4 to the IRS. A withholding agent

may, in addition to Form 8966, also have to file Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, and Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, to report any tax withheld under chapter 4. For further information, see Forms 1042, 1042-S, and their instructions.

• PFFI (including a Reporting Model 2 FFI) or RDCFFI electing chapter 61 reporting. A PFFI

2 Instructions for Form 8966 (2025)

(including a Reporting Model 2 FFI) or RDCFFI that elects to perform chapter 61 reporting to satisfy its chapter 4 reporting requirements for certain accounts is not required to report on Form 8966 with respect to such an account that is held by a specified U.S. person. Instead, the PFFI (including a Reporting Model 2 FFI) or RDCFFI shall report such account on Form 1099. See Regulations section 1.1471-4(d)(5). With respect to an account held by a passive NFFE with a substantial U.S. owner or an account held by an FFI that the PFFI (including a Reporting Model 2 FFI) or RDCFFI has agreed to treat as an ODFFI, the PFFI (including a Reporting Model 2 FFI) or RDCFFI that elects reporting under chapter 61 must still file Form 8966 to report such accounts.

• U.S. branch that is treated as a U.S. person. A U.S. branch that is treated as a U.S. person must file Form 8966 in the same manner as a withholding agent (see earlier). See Regulations sections 1.1471-1(b)(135) and 1.1441-1(b)(2)(iv).

• Territory Financial Institution that is treated as a U.S. person. A Territory Financial Institution that is a flow-through entity or that acts as an intermediary with respect to a withholdable payment and that agrees to be treated as a U.S. person must file Form 8966 in the same manner as a withholding agent (see earlier). See Regulations sections 1.1471-1(b)(131) and 1.1471-2(a)(2) (iv).

Combined Reporting Following a Merger or Bulk Acquisition of Accounts If a PFFI (including a Reporting Model 2 FFI) (successor) acquires accounts of another PFFI (including a Reporting Model 2 FFI) (predecessor) in a merger or bulk acquisition of accounts, the successor may assume the predecessor’s obligations to report the acquired accounts on Form 8966 for the calendar year in which the merger or acquisition occurs, provided the requirements in Regulations section 1.1471-4T(d)(2)(ii)(G)(1) through (4) are satisfied.