2015 New Year Timeline
Jan 1
  • Withhold on FDAP payments to undocumented pre-existing NPFFIs (prima facie FFIs)
  • PFFIs begin due diligence monitoring by PFFIs for certain de minimis accounts for account balances or values >$1 million
Mar 15
  • Introduction of the 1042-S reporting returns covering the 2014 reporting year. Most banks we expect will ask for a one month delay and will therefore file their 1042-S re-porting by April 15th
  • 1042 reporting is also March 15th. Most bank we again ex-pect will ask for a 6 months extension under the 7004 form system
Mar 31
  • 1042-S reporting for USWAs, WAs, and PFFIs 
  • Reporting on Forms 1042 and 1042-S regarding US FDAP payments to foreign entity recipients begins
  • USWAs and PFFIs begin reporting of owner-documented FFIs 
  • USWAs and PFFIs report owners of documented FFIs 
  • USWAs begin reporting of US substantial owners of pas-sive NFFEs 
  • USWAs report on NFFEs with substantial US owners 
  • US account reporting for PFFIs (year-end 2014)
Jun 30
  • FFIs complete due diligence for high-value (HV) individual accounts 
  • PFFIs must complete due diligence on high-value accounts within one year of the effective date of their FFI agreement
Jul 1
  • FFIs begin withholding on US FDAP payments to recalci-trant high-value pre-existing accounts
Sep 30
  • FFIs covered by a Model 1 IGA begin reporting
Dec 31
  • Due diligence for pre-existing accounts 
  • PFFIs perform first annual review of year end balances or values of individual accounts for requirement to perform enhanced review if balance >$1 million 
  • Transition Rules