Global

FATCA - Background 

The Foreign Account Tax Compliance Act (FATCA) is legislation that has been enacted by the US Congress to fund the employment boosting measures included in President Obama’s HIRE Act. The purpose of FATCA is straightforward. It aims to ensure certain US investors with financial accounts outside of the US pay tax on their income. To achieve this, FATCA will require all global financial institutions – not only banks – to report the names and account details of all US persons on an annual basis. To kick start the process, all foreign financial institutions will be able to enter into an agreement with the US Internal Revenue Service by July 1, 2013, committing them to meet a series of reporting and withholding obligations.

Key FATCA dates

March 18, 2010 – FATCA is signed into law


August 27, 2010 – IRS delivers first preliminary guidance, Notice 2010-60


April 8, 2011 – IRS delivers second preliminary guidance, Notice 2011-34


July 14, 2011 – IRS delivers transition preliminary guidance, and Notice 2011-53


December 31, 2011 – IRS is expected to deliver proposed FATCA preliminary guidance

The FATCA rules are important as they contain two strong levers to ensure compliance:


  • Individual account compliance: Foreign financial institutions may be required to withhold 30 percent on US source FDAP* income and the sale or other disposition of a US equity or debt obligation issued by a US person that is not adequately documented, and remit it to the IRS.

  • Financial institution compliance: Where a financial institution is passing a payment onto a second financial institution that has not yet entered into an agreement with the IRS, the first financial institution will be required to withhold 30% on all US sourced payments unless the financial institution discloses all US account holders.

The FACTA challenge is unique for several reasons.


  • FATCA is not just a tax issue. The FATCA legislation will impact financial institutions along several points in their client value chain. They will need additional client data, new reporting mechanisms and systems to deliver them. Implementing the necessary changes, that are required by the effective date, will be intensive and difficult to achieve as it crosses many different internal groups and requires different technical expertise.

  • FATCA requires global coordination. To prepare for FATCA, financial institutions will need to coordinate FATCA implementation across different jurisdictions, reconciling several national legal frameworks.

Contact us for more information at FATCA@kpmg.com



*FDAP – Fixed, Determinable, Annual, Periodical

Get in touch with KPMG

 Contact

David M Neuenhaus

David M Neuenhaus

Global FATCA Lead Partner

+1 973 912 6348

Laurie Hatten-Boyd

Laurie Hatten-Boyd

Global FATCA Tax Lead

+1 206 913 4489

Laurence Birnbaum-Sarcy

Laurence Birnbaum-Sarcy

Global FATCA Advisory Risk Consulting Lead

+1 212 872 5808