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FFI registration portal opening and FATCA deadlines delayed by the IRS - 18/07/2013


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FFI registration portal

The IRS has released Notice 2013-43 pushing back the FFI registration portal opening and extending most of the FATCA deadlines established by the final regulations. The FFI registration portal is now projected to open on 19 August 2013, a little over a month later than previously planned. The IRS also indicated that the opening will be a soft launch, when FFIs will get the chance to start setting up their profiles and adding entities without actually committing to signing or registering, until 1 January 2014. On or after 1 January 2014, FFIs will be able to finalize their registrations through 25 Apri, 2014 to appear on the first IRS FFI list to be posted on 2 June 2014.

Compliance deadlines

The IRS also extended other compliance deadlines including withholding and pre-existing account remediation by 6 months. The first reporting year is 2014 instead of 2013 previously.

QI Agreement

The QI Agreement that would otherwise expire on 31 December 2013 will be automatically extended until 30 June 2014.

Updated Timeline Summary

FATCA Compliance Action Items Old date New date
General Compliance Registration Portal Projected Opening Date 15 July 2013 19 August 2013
GIIN Registration Deadline for first 2014 list 25 October 2013 25 April 2014
First 2014 GIIN list 2 December 2013 2 June 2014
Last date to register for GIIN before withholding begins(1) 31 December 2013 30 June 2014
Effective date of FFI Agreement for registrations before withholding begins 31 December 2013 30 June 2014
Transition Period for affiliated group rule 1 January 2016 No change
New / Preexisting Accounts USWA and FFI begin new account onboarding 1 January 2014 1 July 2014
Cutoff date to determine preexisting account population(2) 31 December 2013 30 June 2014
Initial account balance determination date for de-minimis rules and high value account rule 31 December 2013 30 June 2014
USWA/FFI complete preexisting Prima Facie FFI accounts 30 June 2014 31 December 2014
USWA/FFI complete all other preexisting entity accounts 31 December 2015 30 June 2016
FFI complete preexisting high value individual accounts 31 December 2014 30 June 2015
FFI complete all other preexisting individual accounts 31 December 2015 30 June 2016
Chapter 3, QI/WP/WT Agreements, and Foreign-Targeted Registered Obligation Rules New expiration date for withholding certifications and documentary evidence for Chapter 3 that are set to expire this year 31 December 2013 30 June 2014
New expiration date for Qualified Intermediary, Withholding Partnership, and Withholding Trust agreements set to expire this year 31 December 2013 30 June 2014
End date of Notice 2012-20 transition rule to withholding agents paying interest on a registered obligation after March 18, 2012 31 December 2013 30 June 2014
Withholding Begin income withholding (excludes certain offshore payments of U.S. source income) 1 January 2014 1 July 2014
Begin offshore U.S. source income payment withholding 1 January 2017 No change
Begin gross proceeds withholding 1 January 2017 No change
Begin foreign -passthru payments withholding 1 January 2017 No change
Reporting Calendar year(s) to report for U.S. Account reporting(3) 2013 & 2014 2014 (for U.S. account identified by 31 December 2014)

(1) Verification of a GIIN is not required for a Model 1 FFI prior to 1 January 2015. Model 1 FFIs will be able to register and obtain a GIIN beginning on 1 January 2014 but will have additional time beyond 1 July 2014 to register and obtain a GIIN to be included in the FFI list before 1 January 2015.
(2) For participating FFIs it may also be the effective date of the FFI agreement if different than 30 June 2014. For registered deemed-compliant FFI it is 30 June 2014 or the date the FFI registers and receives a GIIN.
(3) All other reporting deadlines remain unchanged.

For additional details regarding the information above, please find enclosed the news alert prepared by our US colleagues.

If you have any queries regarding the above, please do not hesitate to contact us.

 

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