Reminders

Reporting on accounts held by nonparticipating For- eign Financial Institutions (FFIs). Participating FFIs (PFFIs) (including Reporting Model 2 FFIs) are not required to report an account held by a nonparticipating FFI in Part II or Part V. Therefore, PFFIs (including Reporting Model 2 FFIs) should not check the box for “nonparticipating FFI” on line 5 of Part II, should not check the pooled reporting type “nonparticipating FFI” on line 1 of Part V, and should not complete line 3 of Part V.

Reporting Model 2 FFI related entities or branches. Reporting Model 2 FFIs may have related entities or branches provided that the conditions in the Model 2 intergovernmental agreement (IGA) are met, including the requirement that the related entity or branch reports U.S. accounts to the IRS to the extent permitted. A related entity or branch of a Reporting Model 2 FFI filing Form 8966 should enter the filer category code for limited branch or limited FFI on line 1b of Part I.

Reporting Model 2 FFIs reporting on non-consenting U.S. accounts. 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 (as appropriate). 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.

U.S. branches. On line 1b of Part I, all U.S. branches of an FFI not treated as U.S. persons should enter the filer category code for PFFIs (code 01). All U.S. branches that are treated as U.S. persons should select the filer category code for withholding agents (code 10).