RP-2014-38: FFI Agreement for Participating FFI and Reporting Model 2 FFI

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June 24, 2014

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Issue Number: RP-2014-38

Inside This Issue

Revenue Procedure 2014-38 updates the Model FFI Agreement applicable to foreign financial institutions (FFIs) wishing to enter into an FFI Agreement with the IRS to be treated as a participating FFI under section 1471(b) of the Code. Rev. Proc. 2014-38 also provides guidance to FFIs and branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA) on complying with the terms of the FFI Agreement, as modified by the Model 2 IGA. Rev. Proc. 2014-38 updates the Model FFI Agreement to reflect the temporary regulations released on February 20, 2014, under chapters 3, 4, and 61 of the Code, and section 3406. Rev. Proc. 2014-38 modifies and supersedes Rev. Proc. 2014-13.

Revenue Procedure 2014-38 will appear in the Internal Revenue Bullentin, IRB 2014-29, dated July 14, 2014.

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