• Service: Tax, Topics, Financial Services Regulation
  • Industry: Financial Services, Banking, Investment Management, Insurance, Superannuation, Private Equity, Real Estate & Construction
  • Type: Regulatory update
  • Date: 30/04/2011

FATCA Update

FATCA: Where are we now?
This series provides an update on the status of the Foreign Account Tax Compliance Act (FATCA).

FATCA: Where are we now? Issue 2 - April 2011 

An update on implementation of the Foreign Account Tax Compliance Act (FATCA) as at April 2011. Further guidance has now been released in relation to FATCA in the form of Notice 2011-34, supplementing the previous Notice 2010-60.
FATCA: Where are we now? cover
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The guidance is 46-pages long and includes new guidelines, as well as requests for further submissions on particular points. It expands on the following limited areas:

  • identification of pre-existing U.S. accounts held by individuals (and what processes are required)
  • what is a ‘passthru’ payment (relevant for withholding)
  • types of deemed compliant FFIs (which would be subject to lesser Know Your Customer (KYC) requirements)
  • account data to be reported on U.S. accounts
  • interaction with qualified intermediary rules (a separate US withholding tax KYC regime)
  • treatment of groups with multiple FFIs (expanded affiliate groups)
  • effective dates of FFI agreements.

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