Summary of FATCA Timelines

Withholding (by withholding agents)

2014

July 1

30% U.S. withholding tax will apply to payments of certain U.S. source income (e.g., dividends, interest, insurance premiums) made to non-U.S. financial institutions (FFIs) … Unless FFI establishes by registration it is:

• A participating FFI, including FFIs in Model 2 IGA,
• An FFI in a jurisdiction with a Model 1 IGA treated as in effect, or
• A low-risk FFI

2019

January 1

30% U.S. withholding tax will apply to any gross proceeds from the sale or other disposition after December 31, 2018 of any property of a type that can produce the U.S. source income described above.

TBD

U.S. withholding tax will apply to foreign passthru payment to a recalcitrant account holder or a nonparticipating FFI that is made after the later of December 31, 2018 or the date of the publication of final Treasury Regulations defining the term foreign passthru payment.

Exception: Certain smaller and more local FFIs and exempt beneficial owners (primarily government-owned entities and international organizations) can avoid withholding if they provide the withholding agent with documentation about their status.

Registration (by financial institutions)

2013

August 19

Registration website available for testing purposes only.

2014

January 1

Official opening date to register and obtain Global Intermediary Identification Number (GIIN).

May 5

Final day to register for guaranteed inclusion on first registered FFI list (to avoid withholding).

June 2

First Registered FFI list published – updated monthly thereafter.

2016

January 1

All limited FFI and limited branch registrations will be placed in registration incomplete status on their online FATCA account after December 31, 2015. Limited FFIs and limited branches that seek to continue such status during the 2016 calendar year must edit and resubmit their registrations after December 31, 2015, on the FATCA registration website.

December 31

Sponsoring entities must register their sponsored investment entities and sponsored controlled foreign corporations (CFCs) covered by Annex II of a Model 1 IGA on or before the later of December 31, 2016, and the date that is 90 days after a U.S. reportable account is first identified.

Sponsoring entities must register their sponsored investment entities and sponsored CFCs covered by Annex II of a Model 2 IGA on or before December 31, 2016.

2017

January 1

Sponsoring entities must register their sponsored registered deemed-compliant FFIs and sponsored direct reporting NFFEs by January 1, 2017. Sponsoring entities should consider registering to obtain GIINs well in advance of January 1, 2017, in order to give withholding agents sufficient time to complete the verification requirement.

Reporting (by financial institutions)

2015: Reporting Begins

When to Report

• March 31: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions
• September 30: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to 2014)

1. Account holder’s name.

• For passive non-financial foreign entity, the name(s) of any substantial U.S. owners.

2. Account holder’s U.S. taxpayer identification number (TIN)

• For passive non-financial foreign entity, only the TIN(s) of any substantial U.S. owner(s).

3. Account holder’s address.

• For passive non-financial foreign entity, only the address(es) of substantial U.S. owner(s).

4. Account number.

5. Account balance or value.

6. For accounts held by recalcitrant/nonconsenting account holders: report aggregate number and balance or value.

2016

When to Report

• March 31: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions.
• September 30: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to 2015): Everything reported in 1 through 6 for 2014.

7. Income paid (except certain gross proceeds from the sale or redemption of property).

2017

• March 31: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions.
• September 30: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to 2016): Everything reported in 1 through 7 for 2015.

8. Gross proceeds paid to custodial accounts

2018

• March 31: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions.
• September 30: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to 2017): Everything reported in 1 through 8 for 2016.

2019

• March 31: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions.
• September 30: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to 2018): Everything reported in 1 through 8 for 2017.

2020

When to Report

• July 15: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions.
• December 31: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to 2019): Everything reported in 1 through 8 for 2018.

After 2020

When to Report

• March 31: FFIs in non-IGA jurisdictions and FFIs in Model 2 IGA jurisdictions.
• September 30: FFIs in Model 1 IGA jurisdictions.

What to Report (with respect to previous year): Everything reported in 1 through 8 for 2019.