FATCA: Stay in RO Certification Mode

February 18, 2019

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 the certification period [date you registered the entity in 2015] to 12/31/2018 is available for review and submission. 


Based on your country/jurisdiction of tax residence and FATCA classification, you may be required to submit a periodic certification.


You can submit the certification by selecting "Periodic Certification" under your Available Account Options by the due date.


The due date is July 1, 2019.


Types of FATCA Certifications


Although the certification process is likely fresh in your mind from December  .  .  .  There are two types of certifications that an RO must make on behalf of an entity:

 

  • Certification of preexisting accounts (COPA); and

  • Periodic certification.


The certification timing is based on three-year cycles.  [For more detail regarding certifications, see my blog:  October 29, 2018 FATCA: Some Deregistered Entities Need not Certify;  September 10, 2018 FATCA: Mandatory Certification for GIIN Deregistration].


Front Load Certifications


You should move forward as soon as possible to complete your FATCA certifications rather than wait until July 1, 2019.  Most FATCA and CRS jurisdictions have reporting deadlines from May through July.  If you wait until the July 1 deadline to submit your FATCA certifications, they could get lost in the shuffle.


For those of you who already submitted FATCA certifications in December for earlier registered entities, the information is fresh in your and your staff’s minds.  Given that you completed a comprehensive review of your compliance program in 2018, you should be ready to tackle this new round of certifications.


Don’t Overlook March Certification Deadlines


For most entities, the certification deadline for the period ending December 31, 2017 was December 15, 2018.  However, the certification deadline for a sponsoring entity and a trustee-documented trust is March 31, 2019.

 

For additional blog posts, please go to my website: elizabethmcmorrowlaw.com

 

Please reload

Recent Posts

July 22, 2019

Please reload

Archive
Please reload

  • LinkedIn Clean

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. 

Copyright  © Elizabeth A. McMorrow Law LLC.  All rights reserved.