Q: We are a Sponsoring Entity, and we would like to register our Sponsored Entities. How do we register our Sponsored Entities?
The Sponsoring Entity that agrees to perform the due diligence, withholding and reporting obligations of one or more sponsored entities persuant to Reg 1.1471-5(f)(i)(F) should register with the IRS via the FATCA registration website as a Sponsoring Entity. The Sponsoring Entity can now also register each entity that they are sponsoring on the same FATCA Registration Website and should refer to the updated User Guide for the details.
While a Sponsoring Entity is required to register its Sponsored Entities for those entities to obtain their GIINs, there is a transitional rule that permits Sponsored Entities to use the GIIN of its Sponsoring Entity on its withholding certificates until January 1, 2017. At this time they have to have been registered and have received their own GIIN.