The IRS has published Notice 2016-08 indicating that it intends to amend the chapter 4 regulations to modify the deadline to submit certifications under the FFI Agreement and eliminate the requirement to report gross proceeds paid to accounts held by non-participating FFIs in 2015.
The notice confirms that the first certification period begins on the date the FFI Agreement is entered and ends on 31 December of the following third calendar year and will continue thereafter on three year cycles. Certification of due diligence completion in relation to pre-existing accounts has been extended to coincide with the FFI Agreement certification period (instead of 60 days following the two-year anniversary of the FFI Agreement). In addition, FFIs will not be required to report foreign reportable amounts paid to accounts held by non-participating FFIs in 2015.