Link & Learn - Deloitte United States · 2020-03-23 · • The IFIA have recommended that the...

© 2014 Deloitte & Touche

Link & Learn

FATCA implementation

Eugene O’Keeffe

Alain Verbeken

Martin Killer

Louise Courtney

Cormac Dinan

27 March 2014


Presenters

Cormac Dinan

Director

Deloitte & Touche Ireland

[email protected]

+353 1 417

Martin Killer

Director

Deloitte UK

[email protected]

+44 207 007 0328

Alain Verbeken

Director

Deloitte Luxembourg

[email protected]

+44 207 007 0328

Eugene O’Keefe

Director


[email protected]

+353 1 417 2434

Louise Courtney

Manager


[email protected]

+353 1 417 3088

mailto:[email protected]





Contents

2

3

Key pillars for successful implementation of a FATCA programme 4

FATCA overview

1

Latest technical updates

Key priorities/requirements

5 Deloitte - how we can help?

3 FATCA implementation


FATCA overview


US assets

Fund Insurance

product

Platform IFA / wealth

manager

Custodian

Broker

US owner

Bank

account Trust

Partner

Jurisdiction

Financial

Institutions Income & sales proceeds

IRS concern

• US persons escape their US tax obligations by holding

assets through non-US structures & products.

IRS response

• Non-US financial institutions designated Foreign

Financial Institutions or “FFIs” under draft Regulations,

and Partner Jurisdiction Financial Institutions (when in

a jurisdiction within the IGA network).

• Partner Jurisdiction Financial Institutions will be

required to register with the IRS and report on all US

Reportable Accounts and payments to their respective

Revenue or the IRS.

• Compliance to IRS’ response to be implemented

through a framework of IGAs.

Implications of non-compliance

• Reputation and commercials risks, reporting as

Nonparticipating Financial Institution and application of

regulations.

• Once enacted in legislation, will be a legal requirement

to comply where satisfy Financial Institution definition.

Foreign Account Tax Compliance Act

Overview



Latest technical developments


Latest technical developments Specific considerations in the UK

US FATCA

• UK/US Intergovernmental agreement signed September 2012

• UK Regulations in force as of 1 September 2013 (incorporating US-UK IGA)

• Updated UK guidance released 28 February 2014

UK FATCA

• Agreements signed between the UK and its Crown Dependencies/various Overseas

Territories by the end of 2013 (note only the UK-CD/Gibraltar agreements are reciprocal)

• Final UK Regulations implementing the UK-CD/Gibraltar agreements released March 2014

(note some differences from the regulations implementing the UK/US agreement)

• Draft UK guidance released 3 February 2014 (highlighting differences from US FATCA

guidance)

• Draft CD guidance released 31 January 2014 for consultation (draft CD regulations not yet

released)



Latest technical developments Specific considerations in the UK – US FATCA

Number of key amendments in the latest version of the UK Guidance implementing US

FATCA, including:

• Investment entities – Definition aligned to the US Regulations and further clarity provided

around treatment of investment advisors

• Related entities – Updated position provided on treatment re US accounts

• Holding Companies – Four point test included in relation to whether a Holding Company

will be in scope for PE or similar funds

• Trusts – Further guidance provided with respect to treatment of trusts as financial

institutions and where they may be considered to be professionally managed

• Debt & Equity interests – Regularly traded on established securities market exemption

has been updated to include a number of restrictions on where this can be applied

• Self-Certification – Requirement to establish tax residency under UK Regulations but

Guidance provides some flexibility regarding the timing of recording on systems.

• Relationship Managers – Clarification that only applies to high-value accounts



Latest technical developments Specific considerations in the UK – UK FATCA

Main body of the UK FATCA Agreements broadly in line

with the current US IGAs (including key timings), with

some key differences:

• UK FATCA only impacts FIs in UK and CDs/OTs

• Reportable persons are defined with reference to

residency rather than citizenship and residence.

• The first reporting deadline will be 31 May 2016

• There is an Alternative Reporting Regime for UK

Resident Non-Doms

• No concept of Non-Participating FIs or Recalcitrant

account holders

• No withholding requirements

• No additional registration requirement at present

• No holding company or treasury centre definition

• Specified person definition is different and will include

some FIs

Crown

Dependencies

Overseas

Territories

Guernsey

Isle of Man

Jersey

Anguilla

Bermuda

British Virgin

Islands

Cayman Islands

Gibraltar

(reciprocal)

Turks and Caicos

Islands



Latest technical developments FATCA and beyond

Ireland FATCA

• Ireland and the US signed an Intergovernmental Agreement (IGA) with respect to FATCA

on 21 December 2012.

• On 3 May 2013 Irish Revenue published draft Regulations and draft Guidance Notes

which provide clarity on how Irish financial institutions will comply with the provisions of

FATCA.

• Subsequently, Irish Revenue published updated draft Regulations and draft Guidance

Notes on 7 February 2014. Revenue will accept observations / comments on this updated

draft document up to 21 May 2014 from industry groups and tax practitioners.



Latest technical developments Specific Considerations in Ireland

Exchange Traded

Funds (ETFs)

• Based on an ETF’s activities, it should fall within the definition of an Investment Entity

and will therefore need to register as a FFI.

• Definition of ‘financial account’ in the US-Ireland IGA excludes interests that are regularly

traded on an established securities market.

• The revised draft Guidance Notes have updated details regarding ETFs whose securities

are held through a central securities depository (CSD). It clarifies that it is the members of

the CSD who have responsibility for FATCA reporting, rather than the ETF itself. However,

the notes refer specifically to CREST CSDs. While the IFIA welcomes this, they are still in

discussions with Irish Revenue to clarify the section such that other CSDs, other than

CREST CSDs, are treated in the same manner.

Unit Trust/Variable

Capital

Company/Common

Contractual

Funds/Investment

Limited Partnership

• The funds should fall within the definition of an Investment Entity as these funds invest

money/funds on behalf of other persons (unless it can be classified as a deemed

compliant Financial Institution under one of the exceptions).

• A decision will need to be made as to whether the umbrella fund or the sub-funds will

register as FIs with the IRS – the revised Guidance Notes remain silent on this issue.

• The IFIA have recommended that the guidance notes should be updated to provide that

FFI status is applied at the umbrella level with an option to allow for a sub fund reporting

level for entities that may have a mix of exempt funds and funds subject to FFI status to

reduce the amount of work needed to comply with FATCA.

• An Irish Management Company may benefit from deemed compliant status depending on

the activities undertaken.

Self certification • IFIA is in discussions with Revenue on drafting the relevant forms. 11 FATCA implementation



Luxembourg FATCA

• Announcement of a Model 1 IGA on 21 May 2013.

• Finalisation of IGA Model I announced end of February 2014 (except approval of French

translation)

• Expected publication of IGA before end of March 2014

• Model 1 IGA will waive banking secrecy and allow automatic exchange of information

through Luxembourg tax authorities (IT infrastructure to be defined)



Latest technical developments Specific Considerations in Luxembourg

A couple of key questions

• Is it advisable to register before IGA is signed ?

• Investment funds: registration at fund or sub-fund level ?

• In which case are Soparfi’s to be considered as FFI ?




OECD – Common Reporting Standard (“CRS”)

• CRS released 13 February 2014 based on format of the Model 1 US IGAs that have

already been signed (but some important differences)

• Joint statement released by the ‘Early Adopters Group’ in relation to the CRS released on

19 February 2014, which stated the expected start date for CRS to be no earlier than the

end of September 2017.

• OECD Commentary to CRS expected to be released in coming months

• Alternative forms of self certification may also be released in similar timeframe

Where does this leave us?

• Future proofing of FATCA solution can no longer be ignored

• Identifying tax residency of customers is now the required standard, as opposed to

determining whether a customer is US or not

• The need for an alternative standard form of self certification is now imperative

• Understanding the differences between each set of regulations is critical to ensuring

change is adopted in a robust but efficient manner

• Relationships with multiple tax authorities will need to be managed

• Link with other developments, such as the amended EU Savings Directive, likely to be

applicable as from 2017, and the Administrative Cooperation Directive



1 IGA Expected Soon

2 Actively Engaged

3 Exploring Options

4 US Regulations

IGA concluded Key:

Intergovernmental Agreements


Asia-Pacific Europe

Australia 1 Model 1 Expected

China 1 Model 1 Expected

Hong Kong 1 Model 2 Expected

India 3 Exploring Options Belgium 2 Actively Engaged Jersey Model 1 (Dec 2013)

Japan 1 Model 2 (Jun 2013) Cyprus 1 Model 1 Expected Liechtenstein 2 Actively Engaged

Korea 2 Actively Engaged Czech Republic 3 Exploring Options Luxembourg 1 Model 1 Expected

Malaysia 2 Actively Engaged Denmark Model 1 (Nov 2012) Malta Model 1 (July 2013)

New Zealand 2 Actively Engaged Estonia 2 Actively Engaged Netherlands Model 1 (Dec 2013)

Singapore 1 Model 1 Expected Finland Model 1 ( Mar 2014) Norway Model 1 (April 2013)

Taiwan 2 Actively Engaged France Model 1 (Nov 2013) Romania 3 Exploring Options

Middle East Germany Model 1 (May 2013) Russia 3 Exploring Options

Bahrain 1 Model 1 Expected Gibraltar 1 Model 1 Expected Slovak Republic 2 Actively Engaged

Kuwait 4 US Regulations Guernsey Model 1 (Dec 2013) Slovenia 1 Model 1 IGA initialed

Israel 2 Actively Engaged Hungary Model 1 (Feb 2014) Spain Model 1 (May 2013)

Lebanon 3 Exploring Options Ireland Model 1 (Dec 2012) Sweden 2 Actively Engaged

Oman 4 US Regulations Isle of Man Model 1 (Dec 2013) Switzerland Model 2 (Feb 2013)

Qatar 4 US Regulations Italy Model 1 (Jan 2014) United Kingdom Model 1 (Sep 2012)

Saudi Arabia 4 US Regulations

United Arab Emirates 4 US Regulations

Jordan 4 US Regulations Caribbean Americas

Morroco 4 US Regulations Bahamas 1 Model 1 Expected Argentina 2 Actively Engaged

Barbados 1 Model 1 Expected Brazil 3 Exploring Options

Africa Bermuda Model 2 (Dec 2013) Canada Model 1 (Feb 2014)

Mauritius Model 1 (Feb 2014) British Virgin Islands 1 Model 1 Expected Chile Model 2 (Mar 2014)

Seychelles 3 Exploring Options Cayman Islands Model 1 (Nov 2013) Costa Rica Model 1 (Nov 2013)

South Africa 3 Exploring Options St. Maarten 3 Exploring Options Mexico Model 1 (Nov 2012)


Key priorities/requirements


Exchange of information agreements Key priorities

• Although FATCA impacts a number of areas across businesses there are a number of key work

streams that the industry are currently focussing on which we have set out below.

• Identify a practical approach to identifying Preexisting Financial Accounts as at 30 June 2014

• Consider capabilities to report required information to relevant authorities

• Ensure FATCA compliant onboarding procedures are implemented before 1 July 2014 and future proof solutions.

• Identify gaps in the existing onboarding processes and be able to obtain self certifications for any new accounts.

• Communicate with any relevant service providers to ensure that they will be able to support compliance

Entity

classification and

registration

UK/Irish/Lux

FATCA

Onboarding

Preexisting and

reporting

Key p

rio

riti

es

• Identify and classify entities that fall in-scope of FATCA as FIs

• Confirm strategic approach in advance of registration (ROs, member FIs, sponsoring etc.)

• Register FIs with the IRS and obtain a GIIN in advance of 22 December 2014 efficiently

• Identify impacts of FATCA on existing workstreams/ implementation of new processes

Governance

• Identify Responsible Officers and reflect regional variations to ensure appropriate persons selected

• Ensure a robust governance framework is in place in order to sign off and document key decisions appropriately

• Provide training to Responsible Officers and the wider group of employees



FATCA - Timings in IGA Countries

31 May (UK)/30

June (Ireland)

2015

Exchange of

Reportable

Information in

respect of 2014

31 May (UK)

/30 June

(Ireland) 2016

Exchange of

Reportable

Information in

respect of

calender year

2015

30 June

2014

Accounts

opened on

or before

this date

deemed

‘Pre-

existing’

30 June 2015

Enhanced Review

Procedures for Pre-

existing High Value

Individual Accounts to

be complete

1 Jan 2017

• Withholding on gross

sales proceeds starts

• Possibly, withholding

on passthru

payments starts

30 June 2016

Review

Procedures for

Pre-existing Entity

Accounts and

Lower Value

Individual

Accounts to be

complete

25 April

2014

Deadline for

FI

registration

to ensure

inclusion on

first

participating

FFI list.

1 July 2014

• New

onboarding

goes live

• Income

witholding

commences

(should have

no application

to persons in

IGA countries)

22 December

2014

FATCA registration

for Model 1 IGA

jurisdictions

31 May (UK)

/30 June

(Ireland) 2017

Exchange of

Reportable

Information in

respect of

calender year

2016

2017 2016 2015 2014



Why comply with US FATCA?

Risks for Financial Institutions not achieving compliance

• The IRS is publishing a list of all FATCA compliant global Financial Institutions on 2 June 2014,

businesses have until 25 April 2014 to register (or 22 December 2014 if in a Model 1 IGA country).

1. Reputational

• Many FIs have announced that they will only conduct business with FATCA compliant

counterparties, which could create serous commercial issues for non-compliant FIs.

2. Commercial

• In Model 1 IGA jurisdictions, compliance with FATCA will be mandatory under local law.

• Penalties will be applicable where a Reporting Financial Institution fails to provide/provides

inaccurate information.

3. Legal

• New ‘FATCA-like’ agreements will increase the exchange of information going forward so it is

important to act now to develop an approach that can be adapted.

4. Future proofing



Obligations for Financial Institutions

Classify entities in the

reporting financial institution’s

group. Note a non complying

entity will not prevent

compliance by others

Identifying relevant in scope

Financial Accounts. Search

preexisting individual and entity

accounts to classify them for

FATCA purposes and identify US

Reportable Accounts

Ensure on-boarding processes

capture ‘self certification’ data

and that the reasonableness of

such data can then be

confirmed based on FI’s internal

information

Report information to the

competent authority in

respect of US Reportable

accounts and to immediate

payor in respect of US

Source Payments to

noncomplying Financial

Institutions Register with IRS to report

as required

FATCA

Entity

classification

Preexisting

accounts

classification

New account

requirements

Compliance

Agreements

Reporting

Withholding Achieving

FATCA

compliance

Compliance enforced by various

measures under IGA, including

classification as Non-Participating

where significant non-compliance

and anti-avoidance measures

Withholding in respect of

recalcitrant accounts

removed under Model 1 IGA,

however Non-Participating

FIs in non-partner countries

still subject to withholding on

US sourced withholdable

payments



Key pillars for successful implementation of a FATCA programme


Achieving FATCA compliance The FATCA Funnel methodology

• The regulations can be complicated, especially

where a group operates across a number of

territories (including IGA and non-IGA jurisdictions).

• The diagram opposite shows a structured funnel

approach, which breaks down the requirements into

logical steps aligned with the FATCA obligations.

• It is intended to ensure that efforts are focused on

those areas that are in-scope for FATCA and reach

the ultimate reporting requirement in a streamlined

manner.

• To ensure efficient delivery it is essential that a

strong governance structure is agreed upon and

implemented.

Identify Financial Institution

Identify Financial Accounts

Identify reporting and

withholding requirements

Report information on

relevant accounts to

relevant authority

Update on-boarding of new

Financial Accounts

Classify holders of Pre-existing

Financial Accounts



Phase I Phase II

2014 Activities

• Review draft guidelines

• Complete GIIN

Registration

• Ensure readiness for

new customer on-

boarding from 1st July

• Commence due

diligence activities for

existing customers from

30th June

• Create reporting

solution

2015 Activities

• Complete due diligence

activities (paper search

by 30th June, electronic

search by 31st

December

• Test and deploy

regulatory reporting,

and commence annual

returns

• Commence reporting

withholding obligations

(Model 1) and

withholding (non-Model

1)

Business as usual Project management

• Continue FATCA reporting

• Certify compliance of the FATCA

programme every 3 years

• Regularly review process and

update as required

• Below is an overview of a typical FATCA Programme as applied to a Fund manager. It is critical

that the programme is well integrated to ensure that FATCA controls and processes are built into

business as usual.

Achieving FATCA compliance Programme Overview



Implementation planning Overview

An Implementation should include the following:

Implementation Plan Alignment to Strategy

Consider the key strategic

questions that need to be

addressed at the outset of

implementation

Resourcing Requirements

Provide an indication of the

resourcing requirements

FATCA Work Streams

Identify the key work streams

and their timings

Project Governance

Consider the project governance

structure for the implementation

phase

Dependencies

Identify interdependencies

between work streams

Project Management

Identify who is responsible for

each work stream



Impact within operations infrastructure Key impacts and potential risks

Action Point Key Impacts Potential Risks

Key strategic decisions

Entity

Classification

• Gather entity information and

determine appropriate

classifications.

• Complete registration of FI

entities

• Incorrect technical interpretation

may lead to erroneous

classifications

• Issues with registration or

certification can result in potential

reputational risk

• Who will be responsible for

registration?

• How and when will this be

completed?

Classification of

Preexisting/Update

on boarding of

new Financial

Accounts

• FATCA compliant on boarding

processes

• Develop technology solutions to

support data remediation

• Maintain ongoing compliance

• Enhancements or upgrades

necessary to support FATCA -

requirements may not be fully

implemented by compliance

deadlines

• Non compliant processes

• Application of thresholds

• Identifying relationship mangers

• Future proofing

Governance • Developing a governance

framework and Body of

Evidence

• Update legal documentation,

draft compliance policies and

develop ongoing governance

programs

• Non-compliance with FATCA

policies and procedures internally

or by service providers

• HMRC audit of systems and

processes

• Who is taking overall

responsibility for FATCA

compliance?

• Who will be responsible to

update documents?

• How are you moving from

implementation to BAU?

Identify Reporting

Requirements

• Regular reporting requirements

to HMRC/Irish Revenue.

• Confirm reporting responsibility

• Errors in reporting can impact

FATCA compliance

• Who will be responsible for

reporting?

• Preparation for reporting

milestones



Companies will need to consider controls and a compliance audit trail to make it easier for relationship

managers to understand their responsibilities (where they arise) and provide comfort that the law is

being complied with.

Building the Body of

Evidence

Assurance

Risk based,

efficient

and

sustainable

compliance

Controls design: Embedding FATCA compliance

controls in Business as Usual

and remediation processes

Body of evidence: Supporting legal requirements

and compliance reviews

Assurance Point in time FATCA

programme assurance on the

design, implementation and

readiness for sign off

Model IGA Areas

Governance, Controls and

Assurance Solutions

Review of existing

customers: Individuals

and Entities

Take on processes in

respect of new

customers

Technical tax

interpretation

Project design and

management

Reporting of

information in respect

of U.S. Reportable

Accounts and

Noncomplying

Financial Institutions

Strategy policy and

operating model

Ris

k A

ss

es

sm

en

t

Governance Actions required for compliance



• Finalise Entity classifications and agree an approach for the FFI registration process

• Agree timeline for implementation process

• Prioritises key activities which need to be done now or need to be started due to the length of time

they will take to complete.

• Identify and agree responsibility within the company

• Design appropriate controls – to embed FATCA compliance controls in company processes

• Develop Body of Evidence – to support legal requirements and compliance reviews

Key risks

• There are both internal and external risks involved with enabling FATCA compliance.

• The internal risks are the most significant in the short-term, these include:

- Meeting the resourcing requirements for delivering the programme which may be challenging,

especially during intense periods.

- Ensuring that the company has the FATCA technical knowledge required to interpret the

requirements and provide an audit trail for key decisions.

• The external risks to the programme include further developments in relation to the implementation of

the IGA.

Next Steps Priorities and challenges



Deloitte - how we can help?


Deloitte – how we can help? Deloitte FATCA solutions

• FATCA e-learning modules

• Legal entity registration on IRS portal

• Onboarding process

• Remediation of existing accounts

• Governance and controls

• Programme assurance

• Project Management and Implementation



FATCA eLearning Employee training

• Many FS institutions are currently looking at delivering some

form of FATCA training for employees both for educational

purposes and to act as an important control for ensuring

staff comply with the FATCA requirements

• We have developed two FATCA eLearning modules which

can be incorporated into clients learning management

systems.

Awareness This module is intended to give you an awareness of

FATCA and what its broad requirements are. Learners

will become familiar with the core concepts of FATCA and

the risks of non-compliance. The module is built around a

structured funnel approach which guides learners

through the FATCA requirements and introduces the key

definitions and requirements.

The course takes approximately 20 minutes to complete.

Practitioner This module is intended to provide an in-depth

knowledge of the FATCA due diligence and reporting

requirements. Learners will be introduced to the detailed

requirements for identifying US persons holding

preexisting and or opening new client accounts, as well

as the associated reporting requirements. The content

focuses on a number of worked examples which

reinforce the detailed information provided.

The course takes approximately 40 minutes to complete.



Programme Assurance Deloitte approach to FATCA programme reviews

Requirement Sample deliverables

Deloitte approach

Reviewing the proposed FATCA solution to provide assurance that it

is appropriate to meet the FATCA compliance obligations

Considering the overall programme’s governance structure, timetable

for delivery and resourcing needs to determine whether they were

suitable and reasonable

Benchmarking the FATCA programme’s approach and solution to

other comparable financial institutions organisations

Reviews can be completed through a number of key activities,

including interviews with the programme key stakeholders,

participation in FATCA Steering Committees, desktop reviews and

comparison to industry best practices and benchmarks.

Our team/credentials

Given the complexity of the FATCA requirements, global financial

institutions may require an adviser to review their existing Group

FATCA Programme in order to:

• Confirm if the FATCA requirements identified are complete;

• Assess whether the governance structure is sufficient;

• Identify whether the overall approach is appropriate to enable

efficient compliance (considering inter-dependencies between

areas/business divisions); and

• Compare and benchmark the programme against industry peers

1. Clear, considered approach: We have a tried and tested

approach developed through undertaking projects of this type that

allows us to deliver a robust level of assurance for your

programme.

2. Experienced team: We have assembled a core team that has the

technical expertise, experience of FATCA engagements and deep

industry knowledge required to provide your with comfort around

your interpretation of the FATCA Regulations.

3. Exceptional credentials: We are working with a large number of

institutions to advise on the practicalities of implementing FATCA.

We have therefore undertaken a number of similar assurance

projects and also have the knowledge to support a robust

benchmarking exercise.

Core Element

FATCA program costs1

Solution structure

Governancestructure

International reach

Resourcing

$0 $250MM

Leverage existing Build New

Centralized Federated

Domestic Global

Internal External

Bank 1

Bank 3

Bank 2

Bank 4

GLOBALBANKS

Bank 1

Bank 2

UK HQ BANKS

1 Variation in compilation of cost estimates exist

Co

st

Facto

rs

© 2013 Deloitte LLP. All rights reserved.

Key Findings (1/2)Overview

3

Solution Complexity

Description

FATCA customer aggregation requirements and Bank’s decision to minimize any disruption to customers

has led to a complex solution and increased costs, which is unique to Bank.

Bank has selected a complex technology solution to address FATCA requirements; while possibly a better

long term strategic choice, there are near term financial implications that have not been fully evaluated.

The cost and risks of implementing a new technology solution for Bank are higher than for other banks

which are leveraging existing technology platforms to comply with FATCA regulations.

The solution is based on the US regulations and so further impacts are likely when an IGA is signed and

so future proofing opportunities under the IGA could be considered further.

Implementation

Bank began designing a FATCA solution early based on draft US regulations; other financial institutions

have chosen to delay action to a degree until greater clarity exists.

The coupling of the solution for both new and pre-existing customers was not required under the

regulations and potentially threatens January 1, 2014 compliance deadline for new onboarding

procedures.

A number of delays have already been identified, which will require manual workarounds and this,

combined with the continuing uncertainty over the IGA, threatens the implementation timetable.

Governance

The federated model has led to certain delays and increased costs, through obtaining consensus on

defining requirements and also reduces flexibility in dealing with any changing requirements.

Management has prioritised and focused on the Documentation and Due Diligence sub-program with

Withholding and Reporting starting later, which is appropriate but does mean further costs later,

The program governance structure is consistent with other FATCA programs but there have been certain

delays in communication across the enterprise and various business segments partly caused by the large

number of Steering Committees across Program Core and each of the business segments.

Conclusions

Programme assessment, regulatory benchmarking,

peer benchmarking and recommendations


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