IRS Releases Draft FATCA Compliance Certification Forms, Indicates July 1 Deadline May Be Extended by 90 Days

The Foreign Account Tax Compliance Act (FATCA) requires a foreign financial institution to appoint a “Responsible Officer” who is obligated to submit periodic compliance certifications to the Internal Revenue Service attesting to the institution’s compliance with various FATCA duties.  For most Participating Foreign Financial Institutions (FFIs) and Reporting Model 2 FFIs, the first deadline for their Responsible Officers to submit such compliance certifications is July 1, 2018.  The first certification required to be filed addresses the FFI’s due diligence with respect to pre-existing accounts (referred to as a “Certification of Pre-Existing Accounts”), and the second certification addresses the FFI’s compliance with various FATCA obligations (referred to as a “Periodic Certification”).  Both of these certifications will be used by the IRS to measure each FFI’s FATCA compliance. Yesterday the IRS…

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