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Foreign Financial Institution Reporting: FFI Agreement, Issues for U.S. Taxpayers, Due Diligence, Filing Form 8957

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

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Conducted on Thursday, February 9, 2023

Recorded event now available

or call 1-800-926-7926

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.

Description

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 percent tax from all payments made to the noncompliant FFI.

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. Tax counsel and advisers must prepare for the next stage of reporting requirements of a participating FFI and understand mechanisms for avoiding mandatory withholding of pass-through income.

Listen as our experienced panel provides a detailed discussion for meeting the guidelines for FFIs and their registered individual representatives.

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Outline

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

Benefits

The panel will review these and other important topics:

  • Completing and reporting the required due diligence to the IRS
  • Ensuring an 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

Faculty

Mainguy, Bradley
Bradley Mainguy, JD, LLM

Principal
CohnReznick

Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients...  |  Read More

McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.

Founder/Managing Partner
McCormick Tax

Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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