A commentary on the IRS list (released June 2, 2014) of entities registered for FATCA on the IRS Portal
Posted by William Byrnes on July 9, 2014
This is an excellent analysis of the current FFI GIIN list that everyone should read!
Where to begin?
Perhaps the most revealing aspect of the list released by the IRS last night is those entities not on it. The IRS FAQs reveal that the IRS itself believes that the number of entities yet to register could be as high as 500,000. Many experts would put that number closer to 900,000.
Of the 77,353 entities who registered:
- 70,492 are covered by an IGA (either signed or agreed in substance)
- 586 are in the US or US Territories
- 6,275 are in Non IGA Countries
The 6,275 in Non IGA Countries represent only 8.1% of the total registered. One might draw the conclusion that as more countries enter into IGAs this will draw substantial numbers of entities in those jurisdictions to register on the portal. It does appear that a failure to sign an IGA would explain a lack of critical mass of registrants on the FATCA portal.
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William Byrnes' Tax, Wealth, and Risk Intelligence 
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