In its Notice 2013-69, the U.S. has indicated changes to their Regulations that will introduce a new category of Passive NFFE a Direct Reporting NFFE.
A Direct Reporting NFFE is now described at §1.1472-1(c)(3)* and will be treated as an Excepted NFFE. It will be required to elect to, and report directly to the IRS certain information about it’s direct or indirect substantial U.S. owners. The NFFE will also be required to register with the IRS to obtain its Global Intermediary Identification Number (GIIN).
The Notice also sets out that an Entity will be allowed to sponsor one or more Direct Reporting NFFEs (Sponsored Direct Reporting NFFEs).