Is Anyone at the IRS Reinstating GIINs?
Financial Institutions (FIs) around the world find themselves with terminated FATCA accounts. As a result their Global Intermediary Identification Numbers (GIINs) have been removed from the IRS FFI List and counterparties consider them to be Non-Participating Foreign Financial Institutions (NPFFIs). The costly outcome is that these FIs are subject to FATCA withholding. Although the IRS established a reinstatement process, the process is not working. FATCA Withholdable Payment