In recent years, the U.S. government has increased its efforts to combat offshore tax evasion and the introduction of the Foreign Account Tax Compliance Act (“FATCA”) is the culmination of these efforts. FATCA mandates that participating foreign financial institutions identify U.S. accountholders or suffer a 30% withholding penalty on certain payments.
FATCA was signed into law on March 18th, 2010. The FATCA Final Regulations, issued in January 2013, provide additional detail to help foreign financial institutions (“FFIs”) in their FATCA preparation. FFIs subject to FATCA are required to have a compliance program in place by July 1st, 2014 and responsible FFI officers must certify certain portions of compliance beginning in 2014.
Navigant’s FATCA professionals leverage their expertise in anti-money laundering, operations, regulatory compliance and tax to help financial institutions assess FATCA readiness, develop and implement FATCA policies, and manage the risks associated with FATCA compliance. We specialize in the following FATCA services for our clients:
- Strategy and Policy Development, Implementation and Training
- FATCA FINDSM Pre-existing Account Due Diligence Software
- On-boarding Procedure Updates
- Quality Assurance Reviews and Compliance Assessments
The FATCA Final Regulations were released in January 2013 and give FFIs additional time to implement certain steps to become FATCA compliant. To assist FFIs with the work ahead, we have developed a sample FATCA Implementation Schedule incorporating many of the items discussed in the Final Regulations.
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