HMRC has updated its Guidance Notes in respect of FATCA (‘Foreign Account Tax Compliance Act’).
Strictly speaking, as far as UK firms are concerned, the Guidance Notes relate to the UK Regulations SI 2013/1962 which in turn give effect to the UK/US Agreement under which relevant UK Financial Institutions will report to HMRC and not to the US Internal Revenue Service. Having said that, reporting firms will still need to obtain a GIIN (‘Global Intermediary Identification Number’) which is issued when a firm completes its registration on the IRS Portal.
As a reminder, the reporting of relevant Specified US Persons (and Specified US Controlling Persons) for 2014 needs to be completed by 31 May 2015. The reportable data will gradually increase over the following two years and firms may find the reporting timetable in section 9.3 of the Guidance Notes useful.
The next update of the Guidance Notes will be published in August 2014.
