Canada - English


  • Service: Tax, International Tax Services
  • Industry: Financial Services
  • Type: Business and industry issue
  • Date: 1/29/2014

Key Action Steps Required by Canadian Funds for FATCA Compliance 

FATCA classifies non-US entities under two broad categories - Foreign Financial Institutions (FFIs) and Non-Foreign Financial Entities (NFFEs). The definition of an FFI is broad and captures most funds. A fund and certain non-US entities in its affiliated group may be classified as FFIs, and other non-US entities may be classified as NFFEs.


Each FFI will generally be required to register with the IRS by April 25, 2014, and satisfy other requirements depending on the country where it is organized.

The following are recommended key action steps for Canadian funds:

  1. Review the fund's organizational chart to identify all FFIs in the affiliated group before the registration deadline.
  2. Register each FFI with the IRS before the deadline.
  3. Determine the rules governing each FFI depending on where the entity is organized.
  4. Review the fund's organizational chart to identify the NFFE classification of the entities in its structure and update its withholding documentation.
  5. Analyze payments made by the fund's US entities and determine which entities make FATCA withholdable payments to unrelated non-US parties. Request updated withholding documentation.

KPMG LLP (Canada) has put in place an experienced, multidisciplinary team of tax professionals to help Canadian multinationals meet their FATCA requirements. We are providing FATCA advice to a wide range of financial services and general business organizations and can assist you in determining the FATCA categories for entities in your organization.


If you would like to discuss any aspect of FATCA, please contact your local KPMG adviser.



Russell W. Crawford

Russell W. Crawford

Partner, Tax


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