FATCA reporting requirements

The proposed rules give FFIs additional time to make adjustments to their systems for reporting US income. These reporting requirements will be phased in gradually between 2014 and 2017.

Only identifying information (name, address, TIN and account number) and account balance or value would be reported in 2014 and 2015.

Beginning in 2016, reporting will be required for income payments and in 2017, it could be expanded to include gross proceed payments from the sale of property that generates US-sourced interest or dividends.

Additionally, the proposed regulations provide that the FFI may report information in US dollars or in the currency in which the account is maintained.

The Treasury Department and the IRS are considering whether to require participating FFIs to use the IRS online TIN matching program. This would help FFIs to confirm US account holders have provided the correct name and TIN combination before they file the forms for reporting US accounts with the IRS. If this requirement is adopted, it will go into effect no earlier than 1 January 2015.

To track the number and extent of payments being made to non-participating FFIs, the regulations require, participating FFIs to report the aggregate amount of certain payments made to non-participating FFIs until withholding applies.

The Treasury Department, the IRS and certain foreign governments are considering an alternative approach whereby an FFI could satisfy FATCA reporting requirements if it submits information to its residence country government, and if that government agrees to pass that information on to the IRS. 

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