Comment by foxglacier

Yea I did look at the guide but it's a huge amount of work that I wasn't prepared to do just to make a couple of hundred dollars from one client. Imagine you start at the first option:

Nonparticipating FFI. A nonparticipating FFI means an FFI that is not a participating FFI, deemed-compliant FFI, or exempt beneficial owner.

OK, then what's an FFI, a participating FFI, a deemed-compliant FFI, and an exempt beneficial owner? That's 4 other definitions to look up just to learn you should not choose option 1 of 32. If you keep track of this intermediate knowledge, it can help you skip some other options but you have to look ahead and see that possibility and find a way to store all these intermediate conclusions so that when you wake up the next day you haven't forgotten if you're an exempt beneficial owner or not - and by the way, before you even begin, you have to work out if you're a beneficial owner - exempt or not.

Once you've decided you're not an FFI, you look to see if you're a "Certified Deemed-Compliant Sponsored, Closely Held Investment Vehicle", which doesn't have a definition in the guide! What now? Try to find it in the Internal Revenue code?

By the way, the one you called out - "Excepted Territory NFFE" doesn't actually have a definition at all in the guide either and it refers you to "Regulations section 1.1472-1(c)(1)(iii)". Maybe if you're clever, you can set aside these difficult ones in case you discover an easy right answer first, but that gets back to designing a system to manage the intermediate knowledge and design your search strategy. Yes, you can do it, but also it's stupidly burdensome.