The Internal Revenue Service has released a
FATCA, which was enacted as part of the HIRE Act of 2010, requires foreign financial institutions, including banks and hedge funds, to report on the holdings of U.S. taxpayers to the IRS, or face stiff penalties. The controversial law has provoked protest among foreign banks and governments, along with expatriate U.S. taxpayers and dual taxpayers. That has led to delays in implementation until next July, as well as efforts to repeal in Congress.
Despite the controversy and repeated delays, the IRS and the Treasury Department have been moving forward slowly with implementing FATCA, including the release of draft versions of various form, most recently a draft version of
The draft form asks for the identification of the filer, a Global Intermediary Identification Number that has been developed for FATCA enforcement, in addition to the name of the sponsored foreign financial institution or other intermediary. Part II of the form also requests information on account holder or recipient and their taxpayer information number. A third part of the form asks for the identifying information of U.S. owners who are specified U.S. persons, including their TIN information. Part IV of the form asks for financial information, including the account balance, account number, currency code, interest, dividends, gross proceeds or redemptions, and leaves space for other information.
Separately, the accounting firm Rothstein Kass has released the