The Registration User Guide contains the following instructions for question 13: If the legal name of the IQ, WP or WT has changed since the effective date of the last QI, WP or WT agreement, the financial institution must answer yes. If the “Yes” option is selected, the financial institution must also provide the new legal name of the company QI, WP or WT and the reason for the name change (para. B example, merger, liquidation or change of brand). The financial institution must select “no” if the IQ, WP or WT has not changed its legal name since the date of its last IQ, WP or WT agreement. ii. United Kingdom Financial Institution. The term “UK financial institution or Model 1 FFI” applies to non-US citizens. Companies that meet the definition of a British FFI Model 1. Under the UK agreement, UK companies (including UK branches of non-UK companies) are considered British. Model 1 foreign financial institutions or financial institutions if they belong to one of the following six categories: depositary institution, custodian institution, investment company, specific insurance company, holding company or treasury company concerned.411 Under the regulations, an IFFP includes a FRFI that is described in a Model 2 AGM and that has agreed to comply with the requirements of an FDHA agreement.455 Under the AGREEMENT in Model 2, the term “financial institution” refers to a depositary institution, a custodian institution, an investment company or a specific insurance company.456 2. for a PFFI: any account, instrument or contract maintained, executed or issued by the PFFI that is outstanding at the time of entry into force of the FFI Agreement; and 7. RO and POC. The regulation includes specific verification and certification requirements for FRFIs.

These verification procedures rely on the OR (or agent) to create a compliance program that includes sufficient policies and procedures for the PFFI to meet the requirements of the FFI agreement. The PFFI must regularly review its compliance program. The OR may be any agent of a PFFI or a Model 1 FFI in the FFI EAEC who has sufficient powers to perform the functions of an OR. The OR may designate other individuals to implement and monitor compliance with verification requirements, but it must make all necessary certifications to the IRS.508 Regulations require the OR to certify regularly to the IRS on behalf of the PFFI that the FFI meets the requirements of the FFI agreement.509 A sponsoring organization, a USFI, registering as a Primary FFI, a U.S. A state financial institution or USFI with a foreign branch that renews its IQ agreement or is treated as a reporting financial institution244 under a Model 1 IGA or is Model 1 FFI is required to select “none of the above”. 245,514 In an earlier information notice, the IRS stated that “in a typical case, ro will be the person who signs the FFI agreement.” v. Transitional rules for conducting due diligence on pre-existing obligations. The FFI agreement for a PFFI that registers and receives a GIIN from the IRS by June 30, 2014 will enter into force on June 30, 2014, resulting in a six-month postponement of due diligence periods for existing obligations.73 1. Regulation of IQ and FATCA regimes. Several commentators541 have compared the FATCA and IQ diets, claiming that the FATCA diet does not replace the IQ diet, but goes far beyond. Qi status is purely eligible, while FATCA status is not – it applies to FRFIs that register and enter into FFI agreements with the IRS to avoid FATCA deductions. One.

Identification of the withholding tax agreement with the IRS as QI, WP or WT, question 6a. An IFU that actually has a withholding tax agreement with the IRS to be treated as an IQ, WP, or WT should check the box next to the appropriate status and provide the employer identification number issued to them by the IRS to identify themselves when acting as their IQ. WP or WT. In addition, the IF must indicate whether it intends to maintain its IQ, WP or WT status. A FINANCIAL INSTITUTION that does not have a withholding tax agreement with the IRS to be treated as IQ, WP or WT should allow “not applicable”. When a user applies for membership as a sponsor, select “Not applicable”. The FFI must choose whether it is an IQ, a WP or a WT, and it must provide an ON. The FFI must receive a GIIN to be FATCA compliant. An IFE in a Model 1 or Model 2 jurisdiction must register, be approved, and receive or retain a GIIN.387 A FATCA-compliant FFI in a Model 1 or Model 2 jurisdiction should not be subject to a 30% withholding tax on U.S. income unless it does not meet the requirements of the Model 1 IGA and local implementing legislation.

or the Model 2 IGA, whichever is true. Both Model 1 and Model 2 intergovernmental agreements can be implemented without having a double taxation agreement or tax information exchange agreement with the United States.388 Figure 8 Comparison of FATCA regulations with Model 1 and Model 2 intergovernmental agreements __ 25/04/14 25/04/14 25/04/14 25/04/14 Initial entry 5. Required for Yes Yes Yes Registration complete on or after 1/1/14 6. IFF the first 6/2/14 6/2/14 6/2/14 6/2/14 6/2/14 published List 7. FFI agreement yes no yes no 8. Sponsored FFI Yes Probably Yes Yes Transitional rule 1/1/16 9. Model 1 FFI No Yes, for No Non transitional rule some Model 1/1/15 1 1 OLI 10. Prima facie FFI Yes Probably Yes Yes Transitional rule 1/1/15 11. Already existing Yes Probably Yes Yes Yes Obligations not paid prima facie FFI transitional rule 7/1/16 12. Offshore Yes Probably Yes Yes Yes U.S. FDAP source payments, if not through transitional rule 1/1/17 ______ FFI Agreement Yes No Yes No, for IFFs residing in Japan 16. Use of FRFs Yes Probably Yes Yes Yes Yes 17.

FFI Pays de Oui, based on Yes, based on Yes, based on Yes, based on Yes, based on tax residency on a local IGA and/or IGA and/or IGA and/or legal deterrence – FATCA Partner FATCA Partner Mination Law Law 18. Classification Yes Yes Yes of FRFIs 19. Custodian Generally defined in General generally defined in General Custodian Bank In general In general the general investment defined in Defined in Defined in Defined in Defined in Defined in Entity Regulations Model 1 IGA Model 2 IGA Model 2 IGA — differs — differs — differs from regulations 22. Uf Limited and Yes , Yes — Yes — Branches Limited by Permanent 12/31/15 Safe Harbor Rule 23. Branch Yes, if Yes, if Yes, if Yes, if Registration Residence in Residence in Residence in non-IGA Partner FATCA Partner FATCA Partner FATCA Partner Country FATCA 24. FFI USA with No Yes No No-QI Branch 25. United States FFI with QI Yes Yes Yes Yes Branch 26. ROs/POC Yes Probably Yes, Probably Yes, Probably Yes, Probably Yes, Probably Yes, By authorization of an authorized agent or delegate or delegate ______ No, in general No, in general No, in general THE FRFIs starting with the American source, if resident, if resident, if resident, if resident FDAP 7/1/14 in FATCA partner it is partner It is possible to pass with- pass with- pass with- pass with- keep the payment the chain chain of payment chain 2. Withheld by Yes, No, if No, if No, if FFI at the beginning gross Resident resident reside in income 1/1/17 FATCA Partner FATCA Partner FATCA Partner FATCA 3. Withholding by possible No, if No, if No, if No, if FFI with foreign source Resident in Passthru payments starting FATCA Partners FATCA Partners FATCA Partners PARTNER 1/1/17 if regulate 4 provide. Retained by Yes, No, generally No, generally No, usually FFI on IFLNFI or starting if resident, if resident, if resident account undisciplined 7/1/14 in FATCA in FATCA Holder for American partners it is Partner it is Partner it is Possible to pass with- pass with- pass with- pass with- maintain payment the payment chain payment chain.

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