Accounts — Instruction 8966 — Instructions for Form

Accounts to be reported. A PFFI, Reporting Model 2 FFI, or RDCFFI required to report as if it is a PFFI must file a separate Form 8966 annually for each account required to be reported, or for each group of accounts for which pooled reporting is permitted, in accordance with the FFI agreement and Regulations section 1.1471-4(d). Such an FFI must report with respect to accounts required to be reported that are maintained at any time during each calendar year. This includes accounts that the FFI is required to treat as U.S. accounts or accounts held by ODFFIs, including accounts that are identified as U.S. accounts following a change in circumstances during such year or due to the expiration during such year of the time period provided in the applicable due diligence procedures for documenting the account holder. Such an FFI must also report accounts that are treated as held by recalcitrant account holders at the end of the calendar year. If an account holder rolls over the amounts in one account into another account (of the same or different type) with the same FFI during the calendar year, do not report the account twice. Form 8966 reporting is required for the following accounts.

U.S. account maintained by a PFFI, Reporting Model 2 FFI, or RDCFFI required to report as if it is a PFFI that is held by a specified U.S. person, and for each substantial U.S. owner (or, in the case of a Reporting Model 2 FFI, each controlling person that is a specified U.S. person) of a passive NFFE for which the FFI maintains the account. File a separate Form 8966 for each substantial U.S. owner (or controlling person) of a passive NFFE (as determined under the Regulations or an applicable Model 2 IGA) that is a specified U.S. person.

Note. See Regulations section 1.1471-5(b) for details on the types of accounts potentially subject to reporting, including depository accounts, custodial accounts, equity or debt interests in certain types of financial institutions, and certain cash value insurance or annuity contracts. Exceptions are provided, including for individual deposit accounts with a balance or value less than $50,000 (unless an election is made to forego the exception) and for certain retirement and other accounts. See Regulations sections 1.1471-5(a)(4) and 1.1471-5(b)(2). Also see Regulations section 1.1471-5(a)(3) concerning who is considered the account holder where the listed holders are certain trusts or agents, or when an account is jointly held.

Account held by an ODFFI, as defined in Regulations section 1.1471-5(f)(3). File a separate Form 8966 to report for each specified U.S. person that owns certain equity or debt interests in the ODFFI described in Regulations sections 1.1471-3(d)(6)(iv)(A)(1) and (2) and 1.1471-4(d) (2)(iii)(D) (excluding certain indirect owners described in Regulations section 1.1471-5(f)(3)(ii)(E)).
Account maintained by a Trustee-Documented Trust that is a nonreporting Model 2 FFI, as defined in the applicable Model 2 IGA. The trustee files a Form 8966 to

report each U.S. account (within the meaning of the Model 2 IGA) of the Trustee-Documented Trust.

Account held by a Territory Financial Institution not treated as a U.S. person. File a separate Form 8966 with respect to each specified U.S. person or substantial U.S. owner of a passive NFFE for which the Territory Financial Institution acts as an intermediary or is a flow-through entity and provides the PFFI (including a Reporting Model 2 FFI) with the information and documentation required under Regulations section 1.1471-3(c)(3)(iii)(G). See Regulations section 1.1471-4(d)(2)(ii)(B)(2).
Accounts for which pooled reporting is permitted. PFFIs may report accounts held by the following persons on a Form 8966 by pooled reporting type: recalcitrant account holders with U.S. indicia, recalcitrant account holders without U.S. indicia, recalcitrant account holders that are U.S. persons, recalcitrant account holders that are passive NFFEs, and recalcitrant account holders of dormant accounts. See Regulations section 1.1471-4(d)(6). A Reporting Model 2 FFI, under the terms of the Model 2 IGA, is required to report certain aggregate information regarding accounts it is required to treat as non-consenting U.S. accounts on Form 8966. If a Reporting Model 2 FFI is reporting a preexisting account that is a non-consenting U.S. account, the Reporting Model 2 FFI should use the pooled reporting category for recalcitrant account holders that are U.S. persons or recalcitrant account holders with U.S. indicia (if the Reporting Model 2 FFI treats the account as a U.S. account based on U.S. indicia, as permitted under Annex I of the Model 2 IGA). If a Reporting Model 2 FFI is reporting a new individual account that has a change in circumstances that causes the Reporting Model 2 FFI to know or have reason to know that the original self-certification is incorrect or unreliable and the Reporting Model 2 FFI is unable to obtain a valid self-certification establishing whether the account holder is a U.S. citizen or resident, the Reporting Model 2 FFI should use the pooled reporting category for recalcitrant account holders with U.S. indicia. (See Part V, Pooled Reporting Type , later.)

Account information to be reported. The following information is reported on Form 8966. See Specific Instructions , later, to determine the information you are required to report based on your filing status.

Account held by specified U.S. persons. Identification of the account holder (name, address, and U.S. TIN), account number, account balance or value, certain enumerated payments with respect to the account (described in Part IV), and such other information as may be required on Form 8966 or by these instructions. See Regulations section 1.1471-4(d)(3)(ii).
Account held by passive NFFE. With respect to a passive NFFE, on a separate Form 8966 for each substantial U.S. owner, the name and address of the NFFE, the identification of the substantial U.S. owner (name, address, and U.S. TIN), account number, account balance or value, certain enumerated payments with respect to the account (described in Part IV), and such other information as may be required on Form 8966 or by these instructions. See Regulations section 1.1471-4(d) (3)(iii).

6 Instructions for Form 8966 (2025)

Account held by ODFFI. With respect to an account held by an ODFFI, the name and address of the ODFFI and, with respect to each specified U.S. person that owns certain equity or debt interests in the ODFFI described in Regulations section 1.1471-3(d)(6)(iv)(A)(1) and (2) (excluding certain indirect owners described in Regulations section 1.1471-5(f)(3)(ii)(E)), identification of the specified U.S. person (name, address, and TIN), account number, account balance or value, certain enumerated payments with respect to the account (described in Part IV), and such other information as may be required on Form 8966 or by these instructions. A separate Form 8966 must be filed for each such specified U.S. person. See Regulations sections 1.1471-3(d)(6)(iv) (A)(1) and (2), and 1.1471-4(d)(3)(iv)(B).
Accounts held by recalcitrant account holders. Report the number of accounts included in the reporting pool and the aggregate account balance or value for such accounts.

Withholding Agent Reporting A withholding agent (other than an FFI reporting accounts maintained by such FFI under the account reporting rules described earlier in Accounts and Withholdable Payments Required To Be Reported ), files Form 8966 to report the following in connection with a withholdable payment.

Amounts paid to an ODFFI. With respect to each ODFFI payee, on a separate Form 8966 for each specified U.S. person that owns certain equity or debt interests in the ODFFI described in Regulations section 1.1471-3(d) (6)(iv)(A)(1) and (2) (excluding certain indirect owners described in Regulations section 1.1471-5(f)(3)(ii)(E)), identification of the ODFFI and specified U.S. person (name, address, and TIN), total of all withholdable payments made to the ODFFI, account balance or value, and such other information as may be required on Form 8966 or by these instructions. A withholding agent is not required to report on Form 8966 on a withholdable

payment made to a PFFI (including a Reporting Model 2 FFI) or a Reporting Model 1 FFI that is allocated to a payee that is an ODFFI on an FFI withholding statement when the PFFI (including a Reporting Model 2 FFI) or Reporting Model 1 FFI includes on the statement the certification described in Regulations section 1.1471-3(c) (3)(iii)(B)(2)(v), provided that the withholding agent does not know or have reason to know that the certification is incorrect or unreliable. See Regulations section 1.1474-1(i)(2).

Amounts paid to a passive NFFE. With respect to a passive NFFE payee, on a separate Form 8966 for each specified U.S. person that is a substantial U.S. owner (or, in the case of a Reporting Model 2 FFI, controlling person), identification of the NFFE and each substantial U.S. owner (name, address, and TIN), total of all withholdable payments made to the NFFE, and such other information as may be required on Form 8966 or by these instructions. A withholding agent is not required to report on Form 8966 on a withholdable payment made to a PFFI (including a Reporting Model 2 FFI) or an RDCFFI that is allocated to a payee that is a passive NFFE with one or more substantial U.S. owners on an FFI withholding statement when the PFFI (including a Reporting Model 2 FFI) or RDCFFI includes on the statement the certification described in Regulations section 1.1471-3(c)(3)(iii)(B)(2) (iv), provided the withholding agent does not know or have reason to know that the certification is incorrect or unreliable. See Regulations section 1.1474-1(i)(1).