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.
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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