Administrative, Procedural, and Miscellaneous Rev. Proc. 2014-38 FFI Agreement for Participating FFI and Reporting Model 2 FFIFfi Agreement for Participating Ffi and Reporting Model 2 Ffi • June 24th, 2014
This revenue procedure updates the agreement entered into by a foreign financial institution (FFI) with the Internal Revenue Service (IRS) to be treated as a participating FFI under section 1471(b) of the Internal Revenue Code (Code) and § 1.1471-4 of the Income Tax Regulations (the FFI agreement) to be treated as a participating FFI and that is published in Revenue Procedure 2014-13 (2014-3 I.R.B. 419). The agreement is being updated to make it consistent with the temporary regulations under chapter 4 of the Code, chapters 3 and 61 of the Code, and section 3406, which were released on February 20, 2014. This revenue procedure also provides guidance to FFIs and branches of FFIs treated as reporting financial
