Overview
IRS Issues Guidance on FATCA Compliance: Today, the IRS issued two revenue procedures providing guidance to financial institutions under the Foreign Account Tax Compliance Act. Rev. Proc. 2017-15 sets forth the final qualified intermediate withholding agreement, which allows foreign persons to enter into an agreement with the IRS to simplify their obligations as withholding agents. Rev. Proc. 2017-16 sets forth the agreement entered into by a foreign financial institution with the IRS to be treated as a participating foreign financial institution under section 1471(b), known as the FFI agreement. The revenue procedure also provides guidance to foreign financial institutions under an applicable Model 2 intergovernmental agreement on complying with the terms of the FFI agreement.