As promised, the IRS, which oversees the Foreign Account Tax Compliance Act, has launched its web link for FATCA registration this morning and the agency and providers are doing what they can to ease what looks like the start of a fairly complicated process.The first step would be for firms to download a 76-page user manual that will guide financial services firms so that they can file the necessary forms to complete website registration. I cannot access the guide or any forms but I was able to glean from the IRS website some interesting bits about the time-frame.
For starters, firms must register, create an account and input the required information, including data about branch operations, the lead financial institution, and expanded affiliated groups as soon as they can. Firms can then access and modify data “for the period from the opening of the FATCA registration website through December 31, 2013.”
However, before January 1, 2014, any information “entered into the system, even if submitted as final, will not be regarded as a final submission, but will merely be stored until the information is submitted as final on or after January 1, 2014,” according to the IRS.
“On or after January 1, 2014,” says the IRS, “each financial institution will be expected to finalize its registration information by logging into its account on the FATCA registration website, making any necessary additional changes, and submitting the information as final.”
So, according to the IRS, financial services firms can use the rest of 2013 “to get familiar with the registration process, to input preliminary information, and to refine that information.”
Yet there are some stones in the road ahead.
“It’s important for fund managers to educate themselves before rushing to register,” says Dan Byrne, a tax principal for professional services firm Rothstein Kass in a statement; Rothstein Kass has just released its FATCA Guide for Alternative Investment Fund Managers. Byrne says that “some important pieces of FATCA guidance” need to be clarified.
“We expect that the Cayman Islands intergovernmental agreement … will be released within the coming months and well in advance of the April 25, 2014 initial registration deadline,” Byrne says.
In addition to the services and consulting firms such as Rothstein Kass and PricewaterhouseCoopers, software and IT services providers are readying wares and services.
Markit, for instance, offers the FATCA Service Bureau, which offers outsourced services such as classifying funds and their corresponding investors, validating client documentation, electronically registering FFIs, calculating withholdings on behalf of funds and annual reporting to the IRS, say Markit officials. The vendor also offers tax domain services via its partner Compliance Technologies International.
We wish you the best of luck as you start your FATCA journey.
Here is a shortened link to the IRS login for financial services firms: http://1.usa.gov/18Fp42p
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