By Dave Olenzak. President and Founder of TWC.
With a few exceptions, Model 2 and non-IGA Foreign Financial Institutions should take notice that they must have completed a Certification of Pre-existing Accounts (COPA) and a Periodic Certification. The COPA must be submitted once to certify that the Financial Institution has cleaned up their existing accounts and the Periodic Certification must be submitted every three years to certify that the data submitted is in accordance with their GIIN agreement obligations. The IRS has issued a notice of intent to begin issuing Default Notices. For those Financial Institutions that are in default, there will be a warning with a 60 day remediation period before a final default notice that will provide 90 days for remediation. At that time they will cancel the GIIN agreement, remove the GIIN, and US sourced income will be taxed at 30%. Financial Institutions should check the GIIN registration site to determine their status.