8 February 2012
The US Treasury Department and IRS recently released proposed regulations that detail their plans to implement the FATCA regime
17 September 2012
The UK Government announced that they were the first country to sign an agreement (model I) with the US to implement FATCA
24 October 2012
The IRS released Announcement 2012-42 delaying certain FATCA requirements
14 November 2012
The Treasury released a second Model Intergovernmental Agreement for Cooperation to Facilitate the Implementation of FATCA
15 November 2012
Denmark is the second country to sign an IGA (model I) with the US
19 November 2012
Mexico and the United States signed an IGA (model I)
18 December 2012
The UK Tax Authority (HMRC) has issued guidance notes and draft regulations implementing the IGA in the UK
21 December 2012
Ireland and the United States signed an IGA (model I)
31 December 2012
Qualified Intermediary and Other Withholding Agreements expiring on this date will be automatically extended until 31 December 2013
2013
First year of FATCA reporting
FFI agreements and reporting forms expected in the 1st quarter 2013
17 January 2013
The US Treasury Department and the IRS released final regulations
31 December 2013
Based on informal but public statements, the deadline for Grandfathered Obligations may be extended from 31 December 2012 to 31 December 2013
Deadline for FFIs to enter into an FFI agreement to ensure that US withholding agents will refrain from withholding on 1 January 2014
1 January 2014
Effective date of an FFI agreement entered into any time before 31 December 2013
Withholding begins on US source FDAP
Requirement to implement new account onboarding procedures for U.S. Withholding Agents, Participating FFIs, and Registered Deemed-Compliant FFIs
30 June 2014
Due diligence to be completed for preexisting accounts held by Prima Facie FFI
31 December 2014
Preexisting individual account for high value clients must be documented by Participating FFIs
15 March 2015
Reporting 1042-S on withholdable income payments (US source FDAP income) begins with respect to the 2014 calendar year
31 March 2015
FFIs begin U.S. Account information and balance reporting (with respect to the 2013 and 2014 calendar years)
31 December 2015
All pre-existing account due diligence procedures to be completed for accounts which do not fall under the high value account requirements and for entity accounts which are not Prima Facie FFI
1 January 2016
Each FFI that is a member of an expanded affiliated group must be a participating FFI or deemed-compliant FFI in order for any FFI in the affiliate group to be participating
15 March 2016
PFFIs begin aggregate reporting on NPFFI payments for 2015
31 March 2016
Reporting on U.S. Account income by participating FFIs begins (with respect to the 2015 calendar year.)
1 January 2017
Withholding begins on gross proceeds payments and on passthru payments
15 March 2017
FFIs begin aggregate reporting on NPFFI payments for 2016
31 March 2017
FFIs reporting on prior year gross proceeds of identified US accounts
15 March 2018
PFFIs begin reporting on gross proceeds (1042-S)
The US Treasury Department and IRS recently released nearly 400 pages of proposed regulations that detail their plans to implement the Foreign Account Tax Compliance Act (FATCA), which becomes effective on 1 January 2013.
