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In a recent release, the IRS has announced that the upgrades to its Foreign Account Tax Compliance Act (FATCA) FFI Registration System are now complete, and the system is ready to begin accepting Responsible Officer (RO) certifications. Based on previous IRS communications, RO’s should have at least three (3) months from the date the system opens to provide the certifications. However, the IRS plans to post the official certification deadline on the FFI Registration System webpage between one and two weeks after the system opens. (See our prior discussion on the RO certification deadline).
Recently, the IRS had stated that it was in the process of upgrading the FFI Registration System to include updated classifications, and certification of pre-existing accounts (COPA) and periodic certifications. In conjunction with this upgrade, the Service also began to issue notices to entities requiring them to verify or update their FATCA classifications prior to the completion of the upgrades.
For more information regarding the prior announcement and the FATCA FFI Registration System, see our prior alert: Upgrades to FATCA System generate notices to FFIs Re RO certifications.
With this latest announcement, the IRS has confirmed that the upgrades to the FFI Registration System are now complete, and the system is functional. These updates include a new option to complete and submit COPA and periodic certifications, a new view of COPA and periodic review summary information as well as the ability to view and print submitted certifications, an updated list of FATCA classifications, and the ability to review certification information in a lead financial institutions (FI) member table.
Since the upgrades are complete and the system is ready to begin accepting RO certifications, the IRS is advising all FATCA registered entities to login and update their FATCA classification as soon as possible. For entities with a certification requirement, an update to their FATCA classification is required. Those entities without a certification requirement should also login to the system and update their FATCA classification in order to prevent the receipt of inapplicable certification notices.
More information on FATCA Certifications can be found on the IRS Draft FATCA Certifications webpage.
Finally, for more information on RSM’s FATCA Registration or Responsible Officer Certification services please refer to our FATCA landing page or contact Aureon.Herron-Hinds@rsmus.com.