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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
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)
April 25 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
   
Exception: FFIs in Model 1 IGAs jurisdictions have more time to register and be listed, since withholding agents not required to confirm GIINs before January 1, 2015

 

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

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 2016):
  Everything reported in (1) through (7) for 2015
8. Gross proceeds paid to custodial accounts

After 2017

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 2016

 

Page Last Reviewed or Updated: 23-Oct-2013