A reminder to those firms subject to FATCA that the first return (in respect of 2014) must be submitted to HMRC by 31 May 2015 (‘the reporting date’).
It may be recalled that as far as UK firms are concerned, reporting in accordance with FATCA requirements will be to HMRC and not to the US IRS. Having said that, reporting firms will, of course, still need to apply to the IRS in order to obtain a GIIN (Global Intermediary Identification Number). All firms subject to FATCA requirements should by now have obtained their GIIN, but in case there is still some last-minute housekeeping outstanding an application can be made via the IRS portal.
A link to the latest (August 2014) HMRC Guidance is provided. Section 9.3 (page 169) contains a useful reporting timetable. As will be seen, the information that needs to be reported is being gradually phased-in until 2017.
Although a review of this Guidance was scheduled for February, at the time of this article the August 2014 version is the most recent available.
