It’s the season for Responsible Officer certifications
Responsible Officers ("RO") have long known this day of reckoning was coming - it's finally time for the initial RO Foreign Account Tax Compliance Act ("FATCA") and Qualified Intermediary ("QI") certifications to the U.S. Internal Revenue Service ("IRS").
Draft versions of foreign financial institution ("FFI") and Sponsoring Entity certifications have been released by the IRS. The certification platform will be released by the IRS in late July. The IRS will establish the final deadline for submission of certifications once the system goes live; however, FFIs and Sponsoring Entities will have at least three months to make the certifications. In order to prepare, ROs and other points of contact should ensure they have access to the FFI's homepage and have reviewed the certifications to follow up on any open questions. Many clients are currently scheduling health checks to make sure their processes are FATCA compliant and to review the accuracy of their information reporting for the certification period.
While Reporting Model 1 FFIs will not need to complete FFI certifications themselves, they will want to still ensure they have access to their FFI homepage. Additionally, the IRS is adding a number of new FFI types versus the three included during the initial registration process so it will be critical to update this information in order to receive tailored communications on a go forward basis. It's also a good time to complete a review of FATCA compliance as a number of Model 1 IGA jurisdictions such as Ireland are starting to discuss FATCA audits.
QI certifications are also due shortly. For QIs selecting either 2015 or 2016 as their periodic review year, certifications will be due by 1 September 2018. For QIs designating 2017 as their periodic review year, certifications will be due by 1 March 2019. However, these QIs MUST login to their account and select 2017 as their periodic review year no later than 1 September 2018 in order to automatically trigger the extension of time for the certification.
QIs requesting a waiver from periodic review must submit the request, together with their Internal Controls Certification by 1 September 2018. A QI requesting a waiver must select 2015 as its periodic review year; however, the factual information provided to support the waiver request should be in respect of the 2017 tax year.
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