Foreign Account Tax Compliance Act

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1 Foreign Account Tax Compliance Act 7t h March 2012

2 An overview The Foreign Account Tax Compliance Act provisions which were included in the Hiring Incentives to Restore Employment ( HIRE ) Act passed in March 2010 (generally referred to as FATCA ) Provide the Internal Revenue Service ( IRS ) with increased ability to detect U.S. tax evaders hiding their money in foreign accounts and investments Provisions aimed at certain payments made to non-u.s. persons to compel compliance and not meant to collect significant tax Created new Chapter 4 of the Internal Revenue Code ( IRC or Code ) (Provides limited grandfathering exemptions) Impacts Foreign Financial Institutions ( FFI ) and Non-Financial Foreign Entities NFFE"), while imposing new burdens on U.S. withholding agents Generally, withholding does not apply to withholdable payments until January 1, 2014 with transitional relief for payments of gross proceeds and passthru payments 2

3 The basics Documentation IRS Reporting on US A/C Holders Documentation Foreign Financial Institution Account Holders US Payer Withholdable payments Interest, dividends, rents, etc and gross proceeds from the sale of certain US property Operation of withholding on Passthru payments Reporting on NFFE payments IRS Certification or info on substantial US Owners Non-Financial Foreign Entity Investors 3

4 Withholding Withholdable payments defined as: Any US source FDAP income, including interest, dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, and emoluments Any gross proceeds from the sale of any property that could produce US source dividends or interest Interest on deposits at foreign branches of US banks is US source income Excludes income effectively connected with a US trade or business Withholding applies to passthru payments defined as: The term passthru payment means any withholdable payment and any foreign passthru payment Exemptions from FATCA Withholding: Short-term obligations Accounts payable type payments 4

5 The FFI agreement Requires an FFI to enter into an agreement with the IRS or face a 30% withholding tax on passthru payments including withholdable payments Under the agreement, the FFI will be required to: Obtain information on account holders that is necessary to determine if accounts are U.S. Accounts Comply with any required due diligence/verification procedures and certify completion of such procedures Report information on U.S. Accounts Deduct and withhold a 30% tax on any passthru payment to any account holders who do not supply the required information ( recalcitrant account holders ) or other FFIs that do not meet the requirements Comply with IRS information requests Attempt to obtain a waiver of applicable bank secrecy or other information disclosure limitations or close the U.S. account 5

6 Expanded affiliated group Each FFI that is a member of an expanded affiliated group must obtain the status of either a participating FFI or registered deemed-compliant FFI Exceptions allowed to become a participating FFI where one or more of: Its branches cannot satisfy all requirements and are limited branches the FFIs in the expanded affiliated cannot comply if each such FFI is a limited FFI Cease to be limited after December 31, 2015, when it becomes a participating FFI or deemed-compliant FFI, or as of the beginning of the third calendar quarter following the date on which no longer prohibited from complying Limited branches and limited FFIs treated as non participating FFIs subject to 30% withholding Consequence for expanded affiliate group of any failure to achieve compliance in transition period uncertain Previous discussion of coordinated application procedures Lead FFI legally binding authorisation as agent for FFI affiliates, including NFFE Centralised compliance option recognized efficiencies 6

7 Who has to enter into an agreement? A FFI is a foreign entity that either: Accepts deposits in the ordinary course of a banking or similar business; or Commercial banks Savings and Loan Associations Examples: Credit unions Co-operative banking institutions Holds financial assets for the account of others, as a substantial portion of its business; or Broker Dealers Clearing Organisations Trust Companies Custodial banks Custodian of Employee Benefit Plan Is engaged (or holding itself out as being engaged) primarily in the business of investing, reinvesting, or trading in securities, partnership interests, commodities, notional principal contracts, insurance or annuity contracts, or any interest (including a futures or forward contract or option) in such security, partnership interest, commodity, notional principal contract, insurance contract, or annuity contract; or Is an insurance company (or the holding company of an insurance company) that issues or is obligated to make payments with respect to a financial account under any cash value insurance contract and any annuity contract Mutual Funds Funds of Funds ETF Hedge Funds Private Equity Funds Venture Capital Funds Life Insurance companies/products Sovereign Wealth Funds Commodity Pools Managed Funds Collective Investment Vehicles An NFFE is any foreign entity which is not an FFI 7

8 As of February 8, 2012 When do you have to do things- as of February FFI Governance Due diligence for pre-existing accounts Due diligence for new accounts Jan FFI can enter into FFI Agreement online (Note 1) Jul IRS encourages FFIs to sign up by July to ensure readiness by Jan Jul New account opening procedures must be in place to identify US accounts (Note 3) Jul Certify completion of review of preexisting high value individual accounts (Note 2) Jul Complete due diligence for any pre-existing account holder that is a prima facie FFI Jul Complete due diligence for high value accounts Jul Certify completion of account identification procedures and documentation requirements for all other pre-existing individual accounts Jul Complete due diligence for all other pre-existing accounts Jan Two-year transition period ends for "Limited FFIs" and "Limited Branches" (1) IRS may make the online FFI registration system available before Jan (2) As part of the first certification, FFI must certify that it did not have any procedures in place from August 6, 2011 that would assist account holders in the avoidance of FATCA (3) New accounts are generally permitted a 90-day grace period before being treated as recalcitrant (4) Limited reporting includes name, address, TIN, account number, and account balance of each specified US person who is an account holder. For account holders that are NFFEs that are US owned foreign entities, report name, address and TIN (if any) of such entity and each substantial US owner of such entity Withholding Jan Cut-off date for grandfathered obligations Jan FATCA withholding begins on US source FDAP income Jan FATCA withholding begins on gross proceeds Jan FATCA withholding expected to begin for foreign passthru payments Reporting Sep Begin limited reporting for US accounts and aggregate reporting for recalcitrant accounts (calendar year 2013) with respect to accounts identified as of June (Note 4) Mar Begin Form 1042 FATCA reporting Mar Begin Form 1042-S FATCA reporting (calendar year 2014) for US source FDAP income Mar Form 1042-S reporting (calendar year 2015) now includes gross proceeds; as well as foreign reportable amounts paid to NPFFIs Mar Reporting on US accounts (calendar year 2015) required to include income associated with the US account 8

9 Overview of FATCA project plan Proposed Regulations Final Regulations 2012 J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D 2015 Account Opening and Documentation (preexisting) Account Opening and Documentation (new) Preparation for Classification of Individual and Entity Account Holders Execution of Due Diligence: Individual Account Holders Execution of Due Diligence: Entity Account Holders Technology Enhancement (pre-existing and new accounts) Enhanced Client on-boarding process Withholding Reporting Compliance Framework 8 Legal Entity Management 1 Communications 10 Program Governance /1/13 Effective FFI Date Minimal coverage until 7/1/14 for final receipt of documentation and classifications *Design and implementation work may change depending on future guidance and business decisions /1/13 New account opening procedures must be in place to identify US accounts Minimal coverage until 7/1/15 for final receipt of documentation and classifications 1/1/14 FATCA withholding begins on US source FDAP income 7 7/1/14 Complete due diligence for any pre-existing account holder that is a prima facie FFI or high value account 7/1/15 Complete due diligence for all other pre-existing accounts 1/1/15 FATCA withholding begins on gross proceeds 9/30/14 Begin limited reporting for US accounts and aggregate reporting for recalcitrant accounts (calendar year 2013) with respect to accounts identified as of June Long- Term Operations Central Workstreams BU Specific Workstreams Major Regulatory timelines 9

10 Common challenges encountered Identification of key stakeholders across all regions to confirm project scope, logistics, and charter There is often a lack of clarity of the roles in the FATCA change programs Ensure adequate representation of appropriate resources (Operations, Tax, Operations Technology, Legal, Compliance, On-boarding, Products Specialist, Business Front Office) Coordination with Tax to communicate regulatory interpretation Disparate customer on-boarding processes and data models Local differences in processes and products across businesses and regions Coordination of planning, budget, and resources to achieve compliance Use common project plans, standards, reporting mechanisms, tools and templates Foreign laws and private contractual commitments conflict with FATCA requirements, including data protection, privacy, and confidentiality laws 10

11 Progress by industry Banking 80% 0f major banking groups have initiated formal FATCA compliance projects Banks which have not initiated formal projects tend to be either national or regional FFIs Nearly all Global Banks have FATCA programs in progress Major European banks are focusing on product analysis to define FATCA compliance scope Most banks have adopted a centralised approach rather than delegation to business units Many banks are expecting to go into implementation in Q1 2012, having defined and agreed specific changes to their organisations Asset Management Increasing numbers of asset managers have initiated formal compliance projects Significant engagement around lobbying efforts, in particular through Efama Insurance Very few insurers have initiated formal FATCA compliance projects A number of insures have engaged in investigations to support lobbying efforts 11

12 Implementation You can always count on Americans to do the right thing - after they've tried everything else. Winston Churchill 12

13 Recap The FATCA Notices Notice Issued Topics covered /29/ Defined the scope of certain grandfathered obligations 2. Provided initial guidance on what entities would be considered FFIs and NFFEs 3. Set forth the account due diligence procedures with respect to new and preexisting accounts held by individuals and entities 4. Provided initial guidance on the information required to be reported by FFIs with respect to their US accounts and recalcitrant account holders 5. Requested further comments on a number of issues /8/ Modified the account due diligence procedures for preexisting accounts held by individuals 2. Provided initial guidance regarding the definition and identification of passthru payments 3. Provided guidance on initial categories of FFIs that would be deemed compliant with the requirements of section 1471(b) 4. Modified and supplemented the guidance in Notice regarding the reporting required of FFIs with respect to their US accounts 5. Provided initial guidance regarding the interaction of the qualified intermediary (QI) regime and chapter 6. Provided initial guidance regarding the application of section 1471(b) to expanded affiliated groups /14/ Provides for phased implementation of certain requirements under chapter 4 2. Discusses certain substantive and procedural matters 13

14 Multilateral Efforts - The Joint Statement IRS considering intergovernmental partnerships to: Avoid legal impediments to compliance Simplify practical implementation Reduce FFI costs FFIs in FATCA partner countries take a different path to compliance Could eliminate passthru withholding for eligible FFIs France, Germany, Spain, Italy and UK issued a joint statement with US PwC approach Local delivery XLOS teams (tax and advisory combined) Global centres of excellence 14

15 Appendices 15

16 US persons Definition is very wide: Dual citizens of the U.S. and another county U.S. Citizens even if residing outside the United States U.S. Passport holder Born in the US unless renounced citizenship Is a lawful permanent resident of the United States, regardless of where they reside (i.e. a holder of a green card ) or Substantial presence test: a non-u.s. Citizen that is: Physically present in the United States for at least 183 days by counting All the days (at least 31) in the current year 1/3 the days in the immediately preceding year and 1/6 the days in the second preceding year Is not a diplomat, teacher, student or an athlete 16

17 Reporting on U.S. Accounts - FFIs Report the following information with respect to U.S. Accounts held by: A specified U.S. Person, the name, address and taxpayer identification number (TIN) A U.S. owned foreign entity, the name, address, and TIN (if any) of the U.S. owned foreign entity and name, address, and TIN of each substantial U.S. owner The account number Account balance or value Gross receipts, withdrawals or payments from the account 17

18 Privacy laws Local privacy rules: Rules with respect to a financial institution's collection, use, and disclosure of an individual's personal information Required by law, exception may not apply as compliance voluntary Branches may not be able to share account information across borders due to bank secrecy or other disclosure prohibitions 18

19 Due Diligence Indicia of Potential U.S. Status Indicia of potential US status (Preexisting accounts & new accounts) i. Identification of any account holder as a US resident or US citizen; ii. iii. iv. A US address associated with an account holder of the account (whether a residence address or a correspondence address); US telephone number A US place of birth for an account holder of the account; v. A US in care of address, a hold mail address, or a P.O. box address that is the sole address on file with respect to the account holder; Form W-9 Required documentation to establish as a US account Form W-9 establishing US status, or Form W-8BEN and documentary evidence establishing non-us status. Documentary evidence for this purpose is a non-us passport or other similar government-issued evidence of non-us citizenship. If a US birthplace is provided, must obtain written explanation regarding client's renunciation of US citizenship or reason that the client did not acquire US citizenship at birth. Form W-9 establishing US status, or Form W-8BEN and documentary evidence establishing non-us status of the individual account holder. vi. vii. A power of attorney or signatory authority granted to a person with a US address; or Standing instructions to transfer funds to an account maintained in the US Form W-9 establishing US status, or Form W-8BEN, or Documentary evidence establishing non-us status of the individual account holder. Participating FFIs will be entitled to rely on the documentation received from account holders unless it knows or has reason to know that the information contained in such documentation is unreliable or incorrect. 19

20 IRS Deposit System Business View Entity Customer Account Product The impact of FATCA Operational requirements Customers & Accounts Documentation Reporting Withholding and Depositing FATCA impacts People/ Organization Account Opening System Technology KYC Initiate Transaction Data Process Governance Customer db W9 db Document Storage Review Monitor and Maintain Other IRS Client Reporting System Transaction Processing Payment (settlement, wire) Withhold New process PPP Processing Modified process 20

21 Practical Issues of FATCA Set Up: Changes to systems, policies, procedures (KYC, onboarding etc), controls, product brochures, agreements, reporting Training/communications to the wider business Volume of accounts to search for U.S. indicia Resource constraints Ongoing: Annual retesting of account balances Calculation of passthru payment percentages Reporting and withholding obligations to the IRS Monitoring of compliance with the FFI Agreement 21

22 Potential System Issues How to search for US indicia on existing systems? Changes required to update systems to capture relevant information: Completeness? Accuracy/human error? Firm wide/business unit differences Capture/calculate passthru percentage information Completion of forms required by IRS driven by system Electronic submission of data to the IRS 22

23 Customer Identification Required changes to client on boarding procedures: Possible to determine if under the de-minimus threshold? New account holder procedures/information required Existing account holder due diligence required potential remediation/additional information required in the future Standardise procedures at what level to ensure consistency How to deal with recalcitrant account holders? How to monitor changes to existing account holders? 23

24 Contact us Werner Horn: Maadian Botha: Ronell van Staden: Circular 230: This document was not intended or written to be used, and it cannot be used, for the purpose of avoiding US Federal, state or local tax penalties that may be imposed on any taxpayer. This document has been prepared pursuant to an engagement between PricewaterhouseCoopers LLP and its client and is intended solely for the use and benefit of that client and not for reliance by any other person. This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it PricewaterhouseCoopers LLP. All rights reserved. In this document, PwC refers to PricewaterhouseCoopers LLP (a limited liability partnership in the United Kingdom) which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity.

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