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  • FATCA News and updates

    FATCA Small Reporter Tool (SRT)

    We have developed a lodgment tool for reporters with less than 50 individual and 50 organisation reportable accounts. 

    See also:

    Providing your ABN

    To help us with compliance monitoring and reduce the need to contact you, the ABN of the ReportingFI and sponsor (if a sponsor is reporting) can be included in your report. The IRS issued ReportingFI TIN and sponsor TIN elements are mandatory and should always be included in your report.

    Example

    <ns2:ReportingFI>

    <ResCountryCode>AU</ResCountryCode>

    <TIN issuedBy="US">xxxxxx.xxxxx.xx.xxx</TIN>

    <TIN issuedBy="AU">(Insert ABN here)</TIN>

    <Name>XXXXXX</</Name>

    <Address>

     

    <ns2:Sponsor>

    <ResCountryCode>AU</ResCountryCode>

    <TIN issuedBy="US">xxxxxx.xxxxx.SP.xxx</TIN>

    <TIN issuedBy="AU">(Insert ABN here)</TIN>

    <Name>XXXXXX</</Name>

    <Address>

    End of example

    Reporting sponsor GIIN correctly

    The GIIN value of a sponsoring entity is the GIIN issued to the entity when it is acting in its capacity as a sponsor. Sponsors have 'SP' in their GIIN as per the following format: xxxxxx.xxxxx.SP.xxx

    If you have more than one GIIN, care must be taken to ensure they are correctly provided.

    Ensure the sponsor GIIN appears in the Sponsor element. ReportingFI GIIN should appear at the ReportingFI TIN element. (The ReportingFI TIN is the GIIN issued to the entity when it registers as a ReportingFI.)

    Trustee documented trusts (TDTs)

    When reporting for TDTs, the trustee reports on behalf of the trust and is required to register and obtain a GIIN. The Trust itself is not required to obtain a GIIN.

    The trustee GIIN is reported in the Sponsor data element. The trustee’s GIIN should not be reported in the ReportingFI element.

    The details of the Trust are reported in the ‘ReportingFI’ data element.

    For TDTs the TIN field in the ReportingFI element should be removed completely.

    The IRS FATCA XML User Guide (PDF,1.15MB)This link will download a file advises to leave the ReportingFI TIN field blank. However, ATO validation rules require the TIN field within the ReportingFI data element to be removed.

    In the SRT the TIN cell is left blank, refer to the SRT guide.

    Note also that the:

    • sponsor element must be present and completed
    • DocRefId’s should all begin with the Sponsor GIIN
    • the sponsor FilerCategory code must be ‘FATCA609’.

    Account holder United States of America taxpayer identification numbers (TINs)

    If the United States (US) taxpayer identification number (TIN) is not held for a pre-existing account holder, reporting Australian financial institutions must comply with the required due diligence actions outlined in Notice 2017-46 (PDF, 57.30KB)This link will download a file (summarised below).

    If these actions are taken the Internal Revenue Service (IRS) will not determine that there is significant non-compliance for the calendar years 2017, 2018 and 2019.

    Due diligence actions

    Reporting Australian financial institutions must:

    • get and report the date of birth of each account holder and controlling person whose US TIN is not reported
    • annually request any missing US TINs from each account holder
    • before reporting for the 2017 calendar year, search electronically searchable data maintained by the reporting institution for any missing US TINs.

    How to report missing US TINs

    When lodging with the ATO, the requirements for missing US TINs differ for 2017 and 2018 reporting. After due diligence actions have been undertaken:

    • For the 2017 calendar year reports, due to be lodged by 31 July 2018, you must use nine zeros (000000000) to populate the US TIN data element.
    • For the 2018 calendar year reports, due to be lodged by 31 July 2019, you must use nine capital As (AAAAAAAAA) to populate the US TIN data element. ATO systems will be changed to accept nine As and not nine zeros for the 2018 and 2019 reporting periods.

    Consider if your system requires changes to accommodate entering alpha type characters in the US TIN data element.

    Please be aware that some other countries may have already moved to using nine As. This may have impacts for reporting from/for branches in other countries.

    Archiving your reports

    Previously FATCA reports received from Australian reporters were passed onto the US immediately after lodgment. If the IRS advised of any errors requiring correction, we would contact reporters to rectify the errors.

    To accommodate the implementation of the Common Reporting Standard (CRS) there is a new system to receive and transmit reports for FATCA and CRS. Under this system, your FATCA reports may not be sent to the IRS until September 2018.

    Therefore, the ATO will not be advised by the IRS of any errors requiring correction until after this time. Accordingly, we recommend you delay archiving report data to enable any necessary correction activity.

    Wrapper headers

    From 1 January 2019 all FATCA reports must be lodged with wrapper header information. Existing functionality enabling lodgment of reports without a wrapper header will be maintained until 31 December 2018.

    See also:

    Single file limitation and extension of BDE functionality

    Under the system implemented on 1 January 2018, lodgment of FATCA files are limited to a single report per file. The report should contain all of an entity's reportable accounts.

    However current BDE FATCA functionality, which enables the submission of a file for more than one reporting institution, will continue until approximately December 2018.

    ATO FATCA News and updates bulletin

    You can receive an email alert, from the ATO, when we have new information about FATCA reporting.

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    IRS FATCA News and information bulletins

    You can receive an email, from the IRS, that provides the latest IRS news, guidance and other information relating to FATCA by subscribing to the FATCA news and information list on the IRS website.

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    Last modified: 10 Oct 2018QC 56992