2025›Instructions for Form 8966›! or RDCFFI that is not required to file Form 8966
Definitions
Instruction 8966 — Instructions for Form 8966, FATCA Report · 2026-10-03 edition · updated 2026-10-04 · United States
For detailed information about definitions that apply for purposes of FATCA generally, see Regulations section 1.1471-1(b). A Reporting Model 1 FFI or Reporting Model 2 FFI should also refer to definitions that may apply under an applicable IGA or apply pursuant to any applicable domestic law pertaining to its FATCA obligations. Solely for purposes of filing this Form 8966, the following definitions are provided to help guide filers through the process.
Account/financial account. An account or financial account means a financial account described in Regulations section 1.1471-5(b).
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Account holder. An account holder is the person who holds a financial account, as determined under Regulations section 1.1471-5(a)(3).
Account maintained by a PFFI or Reporting Model 2 FFI. An account maintained by a PFFI or Reporting Model 2 FFI means an account that a PFFI or Reporting Model 2 FFI is treated as maintaining under Regulations section 1.1471-5(b)(5).
Branch. A branch means a unit, business, or office of a financial institution that is treated as a branch under the regulatory regime of a country or that is otherwise regulated under the laws of a country as separate from other offices, units, or branches of the financial institution, and includes a disregarded entity of a financial institution. A branch includes units, businesses, and offices of a financial institution located in the country (or jurisdiction) in which the financial institution is a resident as well as units, businesses, and offices of a financial institution located in the country in which the financial institution is created or organized. All units, businesses, or offices of a PFFI located in a single country (or jurisdiction), including all disregarded entities located in such single country (or jurisdiction), must be treated as a single branch.
Branch that maintains an account. A branch, including a disregarded entity, maintains an account if the rights and obligations of the account holder and the FFI with regard to such account (including any assets held in the account) are governed by the laws of the country of the branch or disregarded entity.
Direct Reporting NFFE. A Direct Reporting NFFE is an NFFE that has elected to report its substantial U.S. owners to the IRS pursuant to Regulations section 1.1472-1(c)(3).
Deemed-compliant FFI. A deemed-compliant FFI means an FFI that is treated, pursuant to section 1471(b) (2) and Regulations section 1.1471-5(f), as meeting the requirements of section 1471(b).
Excepted NFFEs. Excepted NFFEs include NFFEs that are QIs, WPs, and WTs, certain publicly traded corporations (including certain affiliates of such corporations), certain territory entities, active NFFEs, excepted nonfinancial entities, Direct Reporting NFFEs, and Sponsored Direct Reporting NFFEs, as described in Regulations section 1.1472-1(c)(1).
Exempt beneficial owner. An exempt beneficial owner is any person described in Regulations section 1.1471-6(b) through (g) and includes any person treated as an exempt beneficial owner under an applicable Model 1 IGA or Model 2 IGA.
Financial institution (FI). An FI is any institution that is a depository institution, custodial institution, investment entity, insurance company (or holding company of an insurance company) that issues cash value insurance or annuity contracts, or a holding company or treasury center that is part of an expanded affiliated group of certain FFIs, and includes a financial institution, as defined under an applicable Model 1 IGA or Model 2 IGA. See Regulations section 1.1471-5(e)(1).
Foreign financial institution (FFI). Except as otherwise provided for certain foreign branches of a U.S. financial institution or Territory Financial Institution, an FFI means a financial institution that is a foreign entity. The term foreign financial institution also includes a foreign branch of a U.S. financial institution with a QI Agreement in effect.
Foreign reportable amount. The term “foreign reportable amount” means the aggregate amount of foreign source payments described in Regulations section 1.1471-4(d)(4)(iv).
Global intermediary identification number (GIIN). A GIIN is a number assigned to a PFFI, Reporting Model 1 FFI, Reporting Model 2 FFI, RDCFFI, and certain other registering entities (for example, a Direct Reporting NFFE). A separate GIIN will be issued to the FFI to identify, among other things, each jurisdiction where the FFI maintains a branch not treated as a limited branch. A Direct Reporting NFFE will be issued only one GIIN, irrespective of where it maintains branches.
Model 1 IGA. A Model 1 IGA means an agreement between the United States or the Treasury Department and a foreign government or one or more foreign agencies to implement FATCA through reporting by financial institutions to such foreign government or agency thereof, followed by automatic exchange of the reported information with the IRS. For a list of jurisdictions treated as having an IGA in effect, see Treasury.gov/Policy-Issues/ Tax-Policy/Foreign-Account-Tax-Compliance-Act .
Model 2 IGA. A Model 2 IGA means an agreement or arrangement between the United States or the Treasury Department and a foreign government or one or more foreign agencies to implement FATCA through reporting by financial institutions directly to the IRS in accordance with the requirements of the FFI agreement, as modified by an applicable Model 2 IGA, supplemented by the exchange of information between such foreign government or agency thereof and the IRS. For a list of jurisdictions treated as having an IGA in effect, see Treasury.gov/Policy-Issues/Tax-Policy/Foreign-Account- Tax-Compliance-Act .
Non-consenting U.S. account. For purposes of a Reporting Model 2 FFI, a non-consenting U.S. account shall have the meaning that it has under an applicable Model 2 IGA.
Non-financial foreign entity (NFFE). A non-financial foreign entity (NFFE) is a foreign entity that is not a financial institution. An NFFE includes a territory NFFE, as defined in Regulations section 1.1471-1(b)(132) and a foreign entity treated as an NFFE pursuant to a Model 1 IGA or Model 2 IGA.
Nonparticipating FFI. A nonparticipating FFI is an FFI other than a PFFI, a deemed-compliant FFI, or an exempt beneficial owner.
Nonreporting FI. A nonreporting FI means an entity that is resident in or established in a jurisdiction that has in effect a Model 1 IGA or Model 2 IGA and that is treated as a nonreporting FI in Annex II of the applicable Model 1 IGA or Model 2 IGA or that is otherwise treated as a deemed-compliant FFI or an exempt beneficial owner under Regulations sections 1.1471-5 or 1.1471-6.
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Owner-documented FFI (ODFFI). An ODFFI is an FFI described in Regulations section 1.1471-5(f)(3).
Participating FFI (PFFI). A PFFI is an FFI that has agreed to comply with the requirements of an FFI agreement with respect to all branches of the FFI, other than a branch that is a reporting Model 1 FFI or a U.S. branch. The term PFFI also includes an FFI or branch of an FFI described in a Model 2 IGA that has agreed to comply with the requirements of an FFI agreement with respect to a branch, and a QI branch of a U.S. financial institution, unless such branch is a reporting Model 1 FFI.
Passive NFFE. A passive NFFE is an NFFE that is not an excepted NFFE. With respect to a Reporting Model 2 FFI filing this Form 8966 to report its accounts and payees, a passive NFFE is an NFFE that is not an active NFFE (as defined in the applicable Model 2 IGA).
Pooled reporting. For purposes of this form, a PFFI is permitted to report recalcitrant account holders (or, with respect to a Reporting Model 2 FFI, non-consenting U.S. accounts) on an aggregate basis in a reporting pool rather than report specific account holder information. With respect to recalcitrant account holders, a reporting pool consists of account holders that fall within a particular type described in Regulations section 1.1471-4(d)(6). With respect to non-consenting U.S. accounts, see Accounts and Withholdable Payments Required To Be Reported for which pooled reporting is permitted, later.
Qualified Intermediary (QI), Withholding Foreign Partnership (WP), Withholding Foreign Trust (WT). A QI is a foreign entity (or foreign branch of a U.S. financial institution) that has in effect a QI agreement with the IRS. A WP is a foreign partnership that has in effect a withholding foreign partnership agreement with the IRS. A WT is a foreign trust that has in effect a withholding foreign trust agreement with the IRS.
Recalcitrant account holder. A recalcitrant account holder is an account holder (other than an account holder that is an FFI) of a PFFI or registered deemed-compliant FFI that has failed to provide the FFI maintaining its account with the information required under Regulations section 1.1471-5(g).
Registered deemed-compliant FFI (RDCFFI). A registered deemed-compliant FFI is an FFI described in Regulations section 1.1471-5(f)(1), and includes a Reporting Model 1 FFI, a QI branch of a U.S. financial institution that is a Reporting Model 1 FFI, and a nonreporting FI treated as a registered deemed-compliant FFI under a Model 2 IGA.
Related entity or branch of a Reporting Model 2 FFI. A related entity or branch of a Reporting Model 2 FFI is an entity or branch treated as a nonparticipating FFI under Article 3(5) of the Model 2 IGA (or any analogous provision in an applicable Model 2 IGA).
Reporting Model 1 FFI. A Reporting Model 1 FFI is an FI, including a foreign branch of a U.S. financial institution, treated as a reporting financial institution under a Model 1 IGA.
Reporting Model 2 FFI. A Reporting Model 2 FFI is an FI or branch of an FI treated as a reporting financial institution under a Model 2 IGA.
Specified U.S. person. A specified U.S. person is any U.S. person described in Regulations section 1.1473-1(c).
Sponsored Direct Reporting NFFE. A Sponsored Direct Reporting NFFE is a Direct Reporting NFFE that has a Sponsoring Entity perform due diligence and reporting requirements on behalf of the Sponsored Direct Reporting NFFE, as described in Regulations section 1.1472-1(c)(5).
Sponsored FFI. A Sponsored FFI is an FFI that is an investment entity, a controlled foreign corporation, or a closely held investment vehicle that has a Sponsoring Entity that performs certain due diligence, withholding, and reporting obligations on behalf of the Sponsored FFI.
Sponsoring Entity. A Sponsoring Entity is an entity that has registered with the IRS to perform the due diligence, withholding, and reporting obligations of one or more Sponsored FFIs or Sponsored Direct Reporting NFFEs.
Substantial U.S. owner. A substantial U.S. owner is a specified U.S. person described in Regulations section 1.1473-1(b). For purposes of filing this form, a Reporting Model 2 FFI reporting an account held by a passive NFFE should substitute the term “controlling person that is a specified U.S. person” for “substantial U.S. owner” and refer to the applicable Model 2 IGA for the definition of controlling person. A territory NFFE that is not an excepted NFFE determines its substantial U.S. owners by applying the 10% threshold in Regulations section 1.1473-1(b)(1).
Territory Financial Institution. A Territory Financial Institution is a financial institution that is incorporated or organized under the laws of any U.S. territory, excluding a territory entity that is a financial institution only because it is an investment entity.
Territory Financial Institution treated as a U.S. per- son. A Territory Financial Institution treated as a U.S. person means a Territory Financial Institution treated as a U.S. person under Regulations section 1.1471-3(a)(3)(iv).
Trustee-Documented Trust. A Trustee-Documented Trust is a trust described as such in a Model 1 IGA or Model 2 IGA.
U.S. account. A U.S. account is any account held by one or more specified U.S. persons. A U.S. account also includes any account held by a passive NFFE that has one or more substantial U.S. owners, or in the case of a Reporting Model 2 FFI, any account held by a passive NFFE that has one or more controlling persons that are specified U.S. persons. See Regulations section 1.1471-5(a) and an applicable Model 2 IGA.
U.S. branch treated as a U.S. person. A U.S. branch treated as a U.S. person is a U.S. branch that is treated as a U.S. person under Regulations section 1.1441-1(b)(2) (iv)(A).
Withholding agent. With respect to a withholdable payment, a withholding agent is a person described in Regulations section 1.1473-1(d).
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Withholdable payment. A withholdable payment is a payment described in Regulations section 1.1473-1(a).
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