FATCA, governed by the FFI agreement under Revenue Procedure 2017-16, requires Foreign Financial Institutions (FFI) to implement customer due diligence procedures, obtain a Global Intermediary Identification Number (GIIN) and, in some cases, withhold on US source payments.
FFIs must also perform annual reporting on US and recalcitrant account holders. Many countries have entered into an Intergovernmental Agreement (IGA) with the US tax authorities through which FATCA compliance is governed by local law.
QI Solutions offers impact analysis as well as implementation projects related all aspects of the FATCA regime. The objective is to guarantee our clients complete planning and implementation for FATCA and the services we provide include:
- Analysis of specific issues regarding the FATCA regime for FFIs, groups of FFIs and other types of entities (e.g., trusts, holdings, foundations) based on the regulatory framework of the country of residence and assistance for the related implementations plans
- Registration service to obtain a GIIN and management of the FATCA profile (e.g., RO/POC modification, terminations, etc.)
- Creating FATCA self-certification forms, including bespoke forms to incorporate certifications required under FATCA
- Review and support in case of changes to the on-boarding system and customer documentation, support to software providers for IT implementation, due diligence activities (e.g., instructions, terms, necessary activities) and preparation of a template for management of the due diligence results
- Assistance with implementation of a FATCA internal compliance program
- Assistance to the Responsible Officer (RO) of FFIs located in a Model 2 IGA country or Participating FFIs with the FATCA Periodic Certification
- Full Form 8966 outsourcing services including FATCA xml file preparation and submission to the IRS via the International Data Exchange Services (IDES)
- Drafting of memorandum and legal opinions
- Training of personnel
FATCA Portal & GIIN
The IRS recently updated the FATCA registration and access systems to provide users with more secure access using Login.gov or ID.me.
Having an updated account is the first step to help you comply with the additional obligations with the FATCA regime.
We offer support for the implementation of current authentication methods and for the management of the FATCA Portal to ensure that all information related to your profile is always up to date.
FATCA Reporting Service – Form 8966
QI Solutions has been issued a FATCA Identification Number (FIN) by the IRS and this allows us to submit Form 8966 on your behalf using our digital certificate, including the request for an extension.
Our FATCA 8966 service is the perfect solution for financial institutions located in Model 2 IGA countries and includes the use of a simple and intuitive Excel template to obtain the necessary data to report, the preparation FATCA xml file, submission to the IRS via the IDES and the receipt of submission confirmation.
In some circumstances, US tax reporting of US clients may also require Form 1099 reporting, another of our core services.
Extension to file FATCA Report
QI Solutions may request an extension on your behalf to extend the due date to file Form 8966. A request for an extension to file must be made before the original due date of the FATCA Report.
The deadline to request an extension to file Form 8966 is March 31.
An automatic 90 days extension to file Form 8966 can be obtained by filing Form 8809-I.
Internal Compliance Program
In order to carry out the requirement of an internal compliance program under the FFI agreement, QI Solutions offers tailored solutions to assist you in preparation and updating policies and procedures, implementation and reviewing procedures required to meet due diligence, reporting and withholding requirements under the FFI agreement.
Contact QI Solutions to find out how we can simplify your compliance and FATCA certification obligations in an efficient and economical manner.
QI Services
FATCA Services
CRS Services
Learn how we can assist your company to improve compliance with the QI rules. We provide a free, no obligation initial consultation.