The U.S. Department of Treasury has announced a statement of mutual cooperation and understanding for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). The statements will serve as a FATCA intergovernmental agreement (IGA) following the Treasury Department’s Model 2 structure for direct reporting by Japanese financial institutions to the U.S. Internal Revenue Service. The Ministry of Finance of Japan and other Japanese government supervisory authorities will direct and enable all reporting Japanese financial institutions to register with the IRS by January 1, 2014, and implement the requirements of an FFI agreement. The participating Japanese financial institutions will request the U.S. taxpayer identification number of their U.S. account holders, and the consent of account holders for reporting. Annually, the financial institutions will report aggregate information about non-consenting U.S. account holders. Subsequent to receiving direct reports from the participating Japanese financial institutions, the U.S. may make group requests to the Japanese Ministry of Finance for information on recalcitrant account holders (non-consenting U.S. accounts and foreign reportable amounts paid to nonparticipating financial institutions that the reporting Japanese financial institution would have reported had it obtained customer consent). The Treasury Department has made the Japanese FATCA statement available on its website including an Annex I covering due diligence for Japanese financial institutions, and Annex II listing deemed-compliant and exempt types of entities and accounts.
Marianne Couch has authored a number of blog posts on form changes related to FATCA regulations. Click here to view her post archive.
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