Financial Institutions under the remit of FATCA have been issued a short extension to register their funds, assets and accounts with the US Internal Revenue Service (IRS). Initially given until the 25th April, Foreign Financial Institutions (FFIs) now have until May 5th to be issued with a Global Intermediary Identification Number (GIIN).
An online portal is provided by the IRS for the purposes of enabling an appointed Responsible Officer to register accounts on behalf of their organisation.
Notably, firms who fail to meet this new deadline will not be included on the first IRS list of FATCA-compliant FFIs, when it is published on June 2nd. Timely registration is strongly encouraged to avoid potential ramifications for suppliers and investors.
The IRS has also come forward to announce that the many countries whose FATCA agreements are still being finalised will be treated as complete. Twenty six countries already have FATCA agreements in place.
Originally legislated in March 2010, the final deadline for organisations to be fully compliant is 1st July 2014. All ‘pre-existing’ accounts entered into before this date are required to comply with FATCA by 31st December 2014. This includes all US financial institutions in addition to international institutions with either US clients, accounts or assets.
Due to the breadth of its application, financial firms affected by FATCA will need to implement a robust compliance program to ensure they are able to meet their ongoing compliance obligations. Due diligence and customer on-boarding processes will need to be updated to ensure they allow for the collection of additional information required by FATCA and any pre-existing gaps are filled.
As part of its ongoing work with a multinational Bank, Xactium has developed a solution for streamlining the Customer On-Boarding process. Using Xactium’s customised solution, the Bank has greatly improved data consistency, ensured data integrity and is now able to produce requested reports in a timely manner.
EisnerAmper, FATCA Reminder for Investment Funds: http://ow.ly/vO71A
Ernst & Young, Global Tax Alert, Notice 2013-43 revises timelines and provides other guidance on FATCA provisions: http://ow.ly/vO6D8
Opalesque, FATCA deadline looms for hedge funds, http://ow.ly/vO76J US
Department of the Treasury, FATCA Archive - Resource Center, http://ow.ly/vSILR