Wealth & Risk Management Blog

William Byrnes (Texas A&M) tax & compliance articles

Errors on the IRS list of “Approved FFIs”?

Posted by William Byrnes on July 9, 2014


Another excellent analysis from Haydon Perryman. From a “glass is half full” perspective, it’s relatively few errors for a large list. At least, that we can be aware given the limited amount of information currently available.

Of course, when all the data starts to flow, a different story may emerge. Treasury has a daunting challenge not to alienate the public and Congress with false positive audit matches of foreign account information compared to self-reported FBARs, 8938’s, and 1040s. At least, tax audit advisors will be kept very, very busy by their international clientele from 2016 through 2018 while the 2015-2017 initial deluge of information exchanged makes it way through the matching system and then audit process.

FATCA & CRS Training. Advice. Consultancy.

Here is a list of potential errors on the IRS list of approved FFIs dated July 1, 2014:

GIIN
FINm
CountryNm
Error Type
A5XSJ3.99999.SL.180
RAWBANK Sarl
CONGO, DEMOCRATIC REPUBLIC OF THE
Wrong ISO3166-1 (last 3 digits of the GIIN) s/b 178
DQANI4.00007.ME.999
NLB Prishtina sh.a., Prishtina
OTHER
“Other” is not a legal jurisdiction
D52QRM.99999.SL.999
IFC Catalyst Fund /Japan/, LP
OTHER
“Other” is not a legal jurisdiction
EMI585.99999.SL.999
INTERNATIONAL BANK ECONOMIC CO-OPERATION
OTHER
“Other” is not a legal jurisdiction
EUJ5WN.00007.ME.999
GRAWE Kosova J.S.C.
OTHER
This may not be an error; GIIN ends in 999 but Kosovo has no ISO 3166-1 Code
FTMA0U.00005.ME.178
UBA Congo Brazzaville SA
CONGO
Wrong ISO3166-1 (last 3 digits of the GIIN) s/b 180
F505Q5.99999.SL.999
IFC Catalyst Fund, LP
OTHER
“Other” is not a legal jurisdiction
F8DB0C.00011.ME.180
Banque Inter. de Credit
CONGO, DEMOCRATIC REPUBLIC OF THE
Wrong ISO3166-1 (last 3 digits of the GIIN) s/b 178
GMPXWL.00013.ME.999
SIGAL…

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