See Also – International Services
Over the past few years, the U.S. government has implemented a number of enforcement programs targeting the international assets of Americans that are designed to ensure income and assets are being properly reported to (and taxed by) the IRS. A key component of this effort is the Foreign Account Tax Compliance Act (FATCA), which requires foreign financial institutions to report information on US accountholders or face significant penalties. Although there have been several delays in implementing the controversial law, the IRS has recently taken a big step in implementation by launching the new online registration system for financial institutions.
The new system is a web-based application that provides a secure environment in which sensitive financial information can be shared and managed. During the registration process an institution receives a Global Intermediary Identification Number (GIIN) which serves as a unique identifier similar to an EIN. Institutions will be required to share this number with other institutions where they maintain accounts or act as payees. Once this number is assigned, the system allows users to update account information including: points of contact, branch information and information about system status updates and other IRS announcements.
Although registration is not required until January 2014, the IRS is encouraging institutions to become familiar with the new reporting system and complete necessary registration steps. Once the deadline has passed, institutions will be required to provide and finalize registration details by logging into their account and submitting the information as final.
The IRS has announced they will publish the first Foreign Financial Institutions list in June 2014 and update it thereafter on a monthly basis. It’s important for institutions to be aware that in order to be included on the first list they need to be registered no later than April 25, 2014.
The IRS has provided several resources for institutions to make the registration experience as seamless as possible. Below we have provided links to the major resources currently available.
- FATCA Registration Overview –pdf
- FATCA Registration Online User Guide – pdf
- Creating a FATCA account for online registration – video
- Logging into a FATCA Account – video
- Recovering a FATCA ID or resetting a FATCA Access Code – video
- Registration System Common Features and Navigation – video
If you have any questions about FATCA or other international tax issues, please contact our International Services team at 302.225.0600, or click here to contact us.