The IRS has given foreign financial institutions (FFIs), such as banks, additional time to update their reporting systems through an amendment to the temporary FATCA regulations.  The Department of Treasury and the Internal Revenue Service have stated, in IRS Notice 2014-59 that withholding agents and payers have an extended time of implementing their new entity account procedures from July 1, 2014 to January 1, 2015.  The amendment date applies specifically to the standard of knowledge required for determining a payee’s or account holder’s “FATCA status” for Chapter 4 purposes.

Keep in mind that the W-8BEN-E form has over 30 different Chapter 4 classifications  – registered deemed compliant FFI, exempt retirement plan, and passive NFFE, to mention a few – making the classification procedure extremely complex.

For more information about FATCA or for help determining your FATCA Chapter4 status, contact us.