Foreign Financial Institution Reporting: Are You Ready for the 2016 FATCA Deadlines?

FFI Reporting Under Model II IGAs, Completing Due Diligence, Filing Form 8957 and More

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Wednesday, February 3, 2016

Recorded event now available

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Course Materials

This CLE/CPE course will provide tax counsel and advisers with a detailed guide to preparing and filing a Foreign Financial Institution (FFI) Agreement. The panel will describe the FFI designation in depth, outline the due diligence and reporting requirements of a participating FFI, and discuss the mechanisms for avoiding mandatory withholding of pass-through income. The speakers will also analyze the model FFI Agreement and offer guidance on accurately completing the Form 8957 disclosures, as well as required documentation and record-keeping.


A significant component of the FATCA reporting regime is the requirement for FFIs to enter into an agreement with the IRS to disclose the identities of U.S. account holders. Any U.S. person making any payments to FFIs that have not entered into an FFI Agreement is required to withhold 30% tax from all payments made to the noncompliant FFI. Additionally, the FFI regulations require a significant informational reporting, with filing deadlines ending in 2016.

The regulations require an initial certification of all due diligence by Sept. 1, 2016. There are two types of Intergovernmental Agreements (IGAs), entered into between the U.S. and the domicile of the FFI, that govern the FFI’s reporting and withholding obligations. FFIs designated under “Model II IGA” must agree to direct and enable other financial institutions in partner jurisdictions to report information about U.S. accounts held in those institutions.

Increasing reporting burdens associated with FATCA continue to challenge both foreign and U.S. taxpayers. Now that the 2016 implementation deadlines are approaching, tax counsel and advisers must prepare for the next stage of the FFI Model II IGA reporting regime.

Listen as our experienced panel provides detailed guidance to meeting the 2016 FATCA implementation guidelines for FFIs and their registered individual representatives.



  1. FFI definitions and requirements
  2. Completing and reporting due diligence
  3. Renewing the FFI Agreement
  4. Filing Form 8957
  5. Case study/illustrations


The panel will discuss these and other important topics:

  • Completing and reporting the required due diligence to the IRS
  • Ensuring FFI Agreement is in place and that the FFI is in compliance with prior obligations
  • Finalizing Form 8957
  • Documenting the FATCA status of entity payees who are not account holders


Yoram Keinan
Yoram Keinan

Partner and Chair, Tax Department
Carter Ledyard & Milburn

Mr. Keinan has over fifteen years of experience in tax law both in the United States and Israel. He focuses on U.S. and...  |  Read More

Carlson, Austin
Austin C. Carlson

Gray Reed & McGraw

As a licensed attorney and a Certified Public Accountant, Mr. Carlson’s practice focuses on corporate...  |  Read More

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