We have come to expect that the U.S. Internal Revenue Service (IRS) will send the FATCA Responsible Officer (RO) an email to alert the RO a message has been posted on the IRS FATCA portal message board. However, in some circumstances, the IRS will only send a message to a Point of Contact (POC) not the RO. What Is a “Responsible Officer”? An RO is the individual in charge of overseeing a Participating Foreign Financial Institution’s (PFFI’s) compliance with the terms of the I

The IRS issued a reminder today re: FATCA RO certifications. "For the certification period ending December 31, 2019 (generally entities that were initially approved in 2016), FATCA Responsible Officer (“RO”) certifications are due no later than December 15, 2020. If an entity that is required to certify does not submit its certifications by the due date, the entity will not be in compliance with its obligations under FATCA. The consequences of being non-compliant may include

The IRS announced today that it is granting an automatic extension of time to submit FATCA Responsible Officer (RO) certifications for an entity with a certification due date of July 1, 2020. The new deadline is December 15, 2020. It is not necessary to file a request for an extension of time with the IRS. If you have an entity with a July 1, 2020 RO certification deadline, your individual Financial Institution account in the IRS FATCA portal will now indicate the new Decembe

Are you getting 2020 off to a constructive start by getting your FATCA files in order? It can be quite a sticking point if you discover that the employee who registered your entity has left the company and your FATCA access code is nowhere to be found. Sure there are challenge questions meant to assist you in resetting the access code, but do you know the name of the hospital where your former employee was born or the name of his first pet? FATCA Login Basics To login to an

Given that the departments usually handling FATCA, CRS and GDPR are swamped with a variety of other year-end tasks, this post may not be welcome . . . but you’ll thank me later! FATCA: Deregister Now & Avoid 2021 Reporting If you sell, liquidate or otherwise terminate a Reporting Foreign Financial Institution (FFI) by December 31, 2019 make sure you deregister it from the IRS FATCA portal. Certain jurisdictions require that a Reporting FFI submit a FATCA report even when the

The Internal Revenue Service (IRS) recently announced that an individual must have her own tax identification number (TIN) in order to be the “responsible party” on the application to obtain an Employer Identification Number (EIN). This change is effective as of May 13, 2019. What’s the difference between a TIN, SSN, ITIN & EIN? TIN: An identification number used by the IRS in the administration of tax laws. A Social Security Number (SSN), Individual Tax Identification Numb

Check your FATCA account in box and you will discover that the second Responsible Officer (RO) FATCA certification season is already upon us and the deadline is July 1, 2019. IRS E-mails The Internal Revenue Service (IRS) has sent out e-mails alerting ROs to check messages in their FATCA accounts. Once you log into your account in the IRS FATCA portal you may discover the following message: Periodic certification is due Type: Action Required Your periodic certification for t

At recent conferences IRS staff announced a change in certification requirements that has not yet been added to the IRS FATCA FAQs. Regardless of the date of initial Global Intermediary Identification Number (GIIN) registration, an entity is now not required to complete FATCA certifications if it deregistered before July 22, 2018. July 22, 2018 Cut-Off Any entity that was deregistered from the IRS FATCA portal prior to July 22, 2018 is not required to submit a COPA or period

The first round of IRS compliance certifications begins this summer. The certification process was supposed to have started last summer but the IRS postponed the deadline. The current deadline is 90 days after the IRS deploys the certifications capability on the IRS FATCA Registration Portal. Deployment is expected in July 2018. What Are the Certifications? There are two certifications. The first is the Certification of Compliance with the Due Diligence Requirements for Pr

FATCA vocabulary has become second nature to those of us actively working on FATCA-related issues. However, clients and newcomers to the world of FATCA may not have a complete understanding of the lexicon. Certain terms are of critical importance especially the words “Responsible Officer” which is frequently abbreviated as “RO”. What Is a “Responsible Officer”? An RO is the individual in charge of overseeing a Participating Foreign Financial Institution’s (PFFI’s) complianc