In a notice dated November 23, 2015, the Internal Revenue Service (IRS) announced that it had  upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System to enable sponsoring entities to register their sponsored entities to obtain a global intermediary identification number (GIIN).

As we had recently reported, sponsored entities (including, for example, Canadian financial institutions covered by the Canada-US  Intergovernmental Agreement) had been granted a one-year extension until  December  31, 2016  to have their own GIINs for FATCA reporting and withholding purposes.

To facilitate this requirement, the FATCA Online Registration System has now been updated so as to enable and facilitate sponsoring entities to add their sponsored entities and, if applicable, sponsored subsidiary branches.

The FATCA Online Registration System User Guide and FAQs have also been updated to account for these enhancements. Additional information on this system can be found on the IRS website at For further information, please see IRS Notice IR-2015-131.