William Byrnes' Tax, Wealth, and Risk Intelligence

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

How to make FATCA even more complicated

Posted by William Byrnes on October 1, 2014

FATCA & CRS Training. Advice. Consultancy.

The September 2014 Award for making FATCA even more complicated goes to the US IRS.

This award is well deserved as with just a little effort this complication could have made been avoided.

The subject is one of country codes. A dry subject even at the best of times but the IRS have managed to make it quite interesting and also made it more difficult for practitioners.

A foreign financial institution (FFI) needs a GIIN. GIINs are provided by the IRS upon completion of registration on the IRS FATCA Portal.

The last three digits of the GIIN contain the ISO 3166 Code of the Country to which the FFI belongs for FATCA purposes.

ISO 3166 Codes are well established:


ISO 3166 Codes also make FATCA slightly easier to wield because the last three digits of the GIIN, in theory, tell you which IGA to apply (if applicable).

It is…

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