Implications of recently updated IRS FATCA requirements

BearingPoint has settled several important interpretation points in its FATCA approach. Some of these may help financial instituations required to report under FATCA to make decisions on their own approaches to the FATCA requirements.

As part of our regulatory watch services these new interpretations points will be incorporated into BearingPoint’s standard FiTAX FATCA and QI reporting platform, allowing all our clients to share in the collective FATCA reporting standardisation without the risks inherent in decisions and implementations by individual institutions.

Two relevant examples include:

1. No aggregation at client account type level. That is, where a client may hold 3 depository and 1 custodial accounts, four separate 8966 forms will be created for FATCA report-ing compliance. BearingPoint believes this more correctly meets the IRS and other IGA requirements than an aggre-gated approach centered on client.
2. The 1042 S category, BearingPoint believes, can be grouped for the same client and reported at grouped level. However, BearingPoint believes that key to granular data management is the ability to divide such groups into their constituent elements (1042-S Pooled, Recipient and non-recipient) at any point in the reporting cycle and as such will provide such functionality in our FiTAX reporting tool.

Please see the full list of interpretation points in the Newsletter below.

We hope FATCA professionals find this update informative, and would warmly encourage you to contact us to discuss how BearingPoint’s integrated FATCA consulting services and reporting platform might be useful to your organisation and the challenges imposed by the FATCA requirements.

BearingPoint has been working on a very wide range of client requirements, ranging from group wide FATCA reporting compliance (including the technology platform enabling such compliance) through to tactical assistance in accelerating in-house FATCA programmes that benefit from gaining access to our global experience base.