According to a recent IRS Notice, your financial institution will be required to file reports on its U.S. accounts by March 31, 2015 and that reporting will only be with respect to the 2014 calendar year, or U.S. accounts identified not later than December 31, 2014.
For 2015 and 2016, a financial institution will be required to report on payments to non-participating FFIs. This brings practical concerns that your financial institution needs to start thinking about whether a participating FFI should transact with a non-participating FFI. The participating FFI will be required to withhold 30 percent of certain payments made to a non-participating FFI.
Your financial institution needs to start taking practical steps to comply with FATCA requirements that commenced on July 1, 2014, and these compliance actions will require harmonizing many moving parts at one time. Although FATCA compliance under such tight deadlines appears to be a difficult task, with the assistance of a U.S. FATCA advisor and with the right planning and strategy, FATCA compliance can be achieved by the deadlines provided.
A FATCA advisor for your financial institution will coordinate inquiries from each division and its customers regarding FATCA compliance. In addition to inquiries regarding the correct tax forms to file, withholding tax issues and the FATCA regulations we will also discuss current FATCA developments with the your financial institution.