Attorney-at-Law

TOO SWIFT ARRIVES AS TARDY AS TOO LATE – REDIVIVUS

In Uncategorized on 12/16/2013 at 17:02

The celebrated FATCA website rollout, though not providing as much blogfodder as its more august sibling the ACA health insurance website, is still worth a word or two.

The latest iteration anent the solution to every FFI’s problem is to be found in IRS Announcement 2014-1, hot off the e-press.

As you FFIs (pronounced “fifi”s), QIs, WPs and WTs were told back on July 12 (see IRS Notice 2013-43), whatever y’all loaded on the site has been saved, but none of it is final.

“Notice 2013-43 notified FIs that any information they entered in the registration system before the formal opening of the IRS FATCA registration website at the beginning of January 2014, even if submitted as final, would not be regarded as a final submission. Consistent with the Notice, all registrations prior to January 2014, including registrations submitted as final before December 31, 2013 (GMT -5), will be treated as initiated but unsubmitted. Thus, on or after January 1, 2014 (GMT -5), every registering FI must revisit its account, make edits to its information if necessary, sign its FFI agreement if registering as a participating FFI, and submit its registration information as final.” Notice 2014-1. at p. 1.

And the GIIN requirements have been pushed back. See my blogpost “A Jigger of GIIN”, 4/9/13, and page 2 of the Notice.

Best holiday wishes to all you FIFIs, QIs, WTs and WPs. And to you, IRS. Keep that blogfodder coming.

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