The Global Intermediary Identifier Number (GIIN)
The GIIN or Global Intermediary Identifier Number is a 19-character identification number issued by the IRS to foreign financial institutions (FFIs) as part of the Foreign Account Tax Compliance Act (FATCA).
The goal of FATCA is to reduce US tax evasion by requiring FFIs such as banks, funds, trusts, asset managers and insurance companies to report certain information to the Internal Revenue Service (IRS) about their US accounts. While insitutions can choose not to comply with this requirement they will be subject to a 30 percent withholding tax on some of their US-sourced payments. In addition, noncompliance could be perceived as an attempt to shield US tax evaders and can create an unnecessary reputational risk for the the institution.
Each of the FFIs is assigned one of five roles:
- LEAD An entity that initiated the FATCA registration process for Member entities.
- SINGLE An entity or branch that has no Member entities.
- SPONSORING ENTITY An entity that will perform due diligence, withholding, and reporting obligations for other entities. A sponsoring entity will receive a separate GIIN that should only be used when it is fulfilling its obligations as a sponsor.
- MEMBER An entity that obtains a GIIN through its corresponding Lead or Sponsoring entity.
- BRANCH An entity that is a “branch” of the main entity – though the documentation is unclear exactly what the IRS means by branch. Each approved branch will be issued a GIIN. If more than one branch is entered with the same country name, then all branches in that country will receive the same GIIN.
FFIs were required to obtain GIINs starting in January 1, 2014.
Alacra published periodic research on the GIIN. Recent examples include:
The IRS publishes a list of institutions that are registered and approved, along with their individual GIINs, on a monthly basis. Alacra monitors these updates and tracks them in the Alacra Authority File Plus. We can cross-reference or append them to your universe of clients or counterparties to help with regulatory reporting requirements.