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IRS FATCA Certification Deadline Is December 15, 2018

The IRS implemented its online FATCA certification process and sent out messages to registered financial institutions this week. Check your registered entity accounts in the IRS FATCA portal to see if you received two messages re: Certification of Compliance with the Due Diligence Requirements for Pre-existing Accounts of PFFIs (Including Reporting Model 2 FFIs) Periodic Certification The IRS sent out messages on July 23. The deadline to complete the online certifications is December 15, 2018. For additional information re: the certification requirements see my previous blogs: July 11, 2018 FATCA: Sub-Certifications as Part of FATCA Compliance June 12, 2018 FATCA: USFIs & Foreign Granto

FATCA: Sub-Certifications as Part of FATCA Compliance

In anticipation of the IRS implementing its online FATCA certification process, now is the time to consider internal FATCA sub-certifications. The FATCA regulations do not require a sub-certification process. However, sub-certifications can be a useful part of the internal control process under a Foreign Financial Institution’s (FFI’s) FATCA policies and procedures. RO Delegation FATCA permits a Responsible Officer (RO) to delegate compliance tasks to other personnel. The RO may require that such personnel complete sub-certifications to provide assurance to the RO that the assigned compliance tasks have been completed. The RO may also delegate FATCA tasks to third-party service providers.

FATCA & CRS: Bahamas Now Open for Registration & Reporting

The Bahamas announced that its AEOI Portal is now open for CRS and FATCA registration and reporting. The key dates are: Deadline for FATCA and CRS registration is Friday August 3, 2018 at 5 PM. Closing Date for FATCA and CRS reporting is Friday August 31, 2018 at 5 PM. As a reminder 5:00 PM Bahamas time is 5:00 PM New York, 10:00 PM London, and Hong Kong 5:00 AM August 4, 2018 / September 1, 2018. Click for the Bahamas Competent Authority AEOI Portal User Guide which was issued on June 26, 2018. The Bahamas requires: FATCA nil reporting CRS no nil reporting Registration for all Reporting FFIs For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com. #Ba

Disclaimer: The information on this website is for general informational purposes only. Nothing on this site should be taken as legal advice. The viewing of this website does not constitute an attorney-client relationship. 

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