14 January 2015
Dear All, We are an general Insurance Company carring general insurance Business. As per FATCA act we have to register ourselves for getting GIN no.. We do not have any branch outside India. Kindly help us on the issue in which category we will have to register ourselves- Participating Foreign Financial Institution (PFFI) or a Registered Deemed-Compliant FFI (RDCFFI) or a Limited FFI (Limited FFI), or a Sponsoring Entity
19 January 2015
Please evaluate whether the GIC is an FFI from FATCA perspective. I beleive it will not be an FFI.
In any case,you will have to register under RDCFFI category - please refer to the IRS announcement 17-2014.
Relevant extract: As described in Notice 2013-43, FFIs resident in, or organized under the laws of, a jurisdiction that is treated as having an IGA in effect, which, pursuant to this announcement includes jurisdictions listed on the Treasury and IRS websites as having reached agreements in substance on IGAs before July 1, 2014, should register on the FATCA registration website as a registered deemed-compliant FFI (which would include all reporting Model 1 FFIs) or a participating FFI (which would include all reporting Model 2 FFIs), as applicable.