THE FIRM BLOG OF FLOTT & CO. PC

Once people and businesses cross borders, they by necessity encounter two legal and tax systems that must be reconciled: their own and the foreign country where they wish to operate.

These publications do not constitute legal advice. Further information regarding this notice.

Recent Articles

IRS Releases List of Foreign Financial Institutions that have received Global Intermediary Identification Numbers

In late May, the IRS published the first list of the Foreign Financial Institutions (“FFI”) that have applied for and received Global Intermediary Identification Numbers (“GIIN’s”). The list is searchable at the IRS website. According to the IRS, the list will be periodically updated.

Recipients of W-8BEN-E’s are now able to independently verify whether an FFI that reports a GIIN on the form is actually registered with the IRS. In addition, since the list is public and can be downloaded, we can learn some interesting facts from the list. Of the current list of 77,354 entries, only 5,605 have the word the word “bank” in their names while 13,813 have the word “fund” in their names.

Probably the most interesting part of the data is the number of FFI’s reported in each jurisdiction. For example, the Cayman Islands is home to 14,837 of the FFI’s or about 19.2% of all of the FFI’s. To put that in perspective, the United Kingdom is home to 6,264 or 8.1% of the FFI’s and Switzerland is home to 4,041 or 5.2% of the FFI’s. It is interesting to see that a single jurisdiction accounts for almost 20% of all of the FFI’s reported and you have to wonder if that high percentage is because there are so many FFI’s in the Cayman Islands or because they have been more proactive in  registering.