The notice also discusses other matters that will be addressed in regulations to be issued by Treasury and the IRS.
- A new mechanism called ’Passthru Payments’ was introduced that may result in previously classified non-US source income being exposed to the withholding regime.
- The due diligence requirements to classify existing clients will be onerous; especially where paper based information needs to be considered (as will be the case for private banking clients).
- FATCA compliance will require significant systems enhancements, changes to the controls and procedures utilised when opening new accounts, and the reworking of many operational processes.
- This will require a devoted, multi-functional, project team.