The Dec. 15, 2018 deadline for all companies registered as reporting foreign financial institutions (FFIs) to login to the IRS FATCA portal to confirm their Chapter 4 status, update their contact information, and submit any required certification of preexisting account due diligence (COPA) and effective internal controls rapidly approaches. Don’t risk noncompliance and potential exposure! The U.S. Internal Revenue Service (IRS) recently reminded reporting FFIs to login to the portal now to confirm their status and submit any required certifications or they may be subject to exposure. (See bulletin).
In light of the IRS’ recent announcement that it intends to focus on FATCA compliance with increased enforcement starting in 2019, it is imperative that companies check their FATCA portal message boards and respond to any action items now.
Companies registered as participating FFIs or Reporting Model 2 FFIs (i.e. residents of Bermuda, Japan, Switzerland, etc.) are required to submit the COPA and periodic certification. Companies registered as Reporting Model 1 FFIs (i.e. residents of the Cayman Islands, United Kingdom and Canada, etc.) are not required to submit any certifications, but should still login to the portal to update or confirm their FATCA status or they will continue to receive notices and risk having their global intermediary identification number (GIIN) revoked, which could mean exposure for 30 percent FATCA withholding on U.S. sourced payments that they receive.
Continue to monitor your FATCA message boards as we expect the IRS to ramp things up after Dec. 15 as they prepare for increased enforcement of FATCA under its new compliance campaign starting next year.
For additional information please refer to our FATCA landing page here. Should you need assistance with completing these certifications, please do not hesitate to contact us.
