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FATCA Timeline for U.S. Withholding Agents

Due diligence for preexisting accounts

  • December 31, 2014 – Expiration date for withholding certificated and documentary evidence that would have otherwise expired on December 31, 2013
  • December 31, 2014 – Complete identification and review of preexisting entity account holders that are prima facie FFIs
  • June 30, 2016 – Complete identification and review of remaining preexisting non-U.S. entity accounts.

Procedures for new accounts

July 1, 2014 - Enhanced account opening procedures must be in place to establish status of new individual accounts

January 1, 2015 – Enhanced account opening procedures must be in place to establish FATCA status of new entity accounts

Withholding

January 1, 2015 - Begin FATCA withholding on preexisting entity account holders that are undocumented prima facie FFIs with respect to U.S. source FDAP income

July 1, 2016 – Begin FATCA withholding on remaining undocumented preexisting entity accounts with respect to U.S. source FDAP income.

January 1, 2017 – FATCA withholding may begin on gross proceeds.

January 1, 2017 – Begin FATCA withholding on payments made by a secured party with respect to collateral.

January 1, 2017 – Begin FATCA withholding on previously excluded off shore obligor payments.

Reporting

March 14, 2015 – Begin Form 1042-S reporting on U.S. Source FDAP income paid from July 1, 2014 through the end of the year.

March 31, 2105 – Begin Form 8966 reporting with respect to U.S. –owned foreign entities and owner documented FFIs from July 1, 2014 through December 31, 2014

March 15, 2018 – From 1042-S reporting for calendar year 2017 must include gross proceeds