We posted IRS Delays FATCA Registration for Six Months! on July 12, 2013, Which discusses IRS 2013-43, which provides for a Six-Month Extension for FATCA Withholding!
This notice provides a six-month extension for when withholding will begin (i.e., payments after June 30, 2014) and for implementing new account opening procedures as well as related requirements to comply with FATCA.
The significant changes that can be found in IRS Notice 2013-43 are:
- FATCA withholding delayed until 7/1/2014
- Customer onboarding delayed until 7/1/2014
- Definition of a preexisting account has been extended to 7/1/2014
- Grandfathered obligation extended to 7/1/2014
- For withholding agents other than PFFIs (for example, USFIs), due diligence on preexisting obligations has been postponed by 6 months. Prima facie FFIs now need to be documented by 12/31/2014; other entities and individuals need to be documented by 6/30/2016
- FFI registration delayed by 6 months.
- Portal comes out 8/19/2013. To get on initial FFI list must be registered by 4/25/2014 to get on initial list that will be published on 6/2/2014
- Due diligence for PFFIs extended by 6 months for each category. However, enhanced review for high-value individuals has been extended by 1 year to 12/31/2015
- Extension of all QI, WP, and WT agreements by 6 months
- Current W-8s and documentary evidence expiring on 12/31/2013 will now expire on 6/30/2014
Undeclared Income from a Foreign Account?
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