What Is an Expanded Affiliated Group (EAG) in FATCA

Offshore Tax with HTJ.tax · Sep 30, 2025 · 5m

An Expanded Affiliated Group (EAG) is defined under Code section 1504(a) and Treas. Reg. §1.1471-5(i). It generally means one or more chains of entities connected through ownership by a common parent. Normally, the parent must directly own more than 50% of another member’s stock or equity interests.In FATCA, the EAG rules are designed to prevent avoidance of reporting obligations. The “one bad apple” rule applies—if any member of the group is a non-participating FFI, then no member can claim participating FFI status.While the definition is based on corporate ownership, trusts or partnerships…