The IRS published its September list of 99,861 FFIs registered for FATCA. But that’s just an increase of about 4,500 registrations since the August list of 95,239. The disappointing September result is a harbinger of the rough waters ahead for general FATCA compliance. Considering the growth in registrations has slowed dramtically from the July to August increase of only 7,246 additional entities (up from 87,993 in July), many industry watchers are sounding the alarm bells.
How Many Foreign Financial Institutions Are Still Not Registered? Most!
Most pundits thought at least 20% of the FFIs requiring FATCA registration would have done so by September - with only 120 days left before the precipice of 30% withholding begins against IGA countries. 120,000 is the minimum number brought up by industry for the September list that would need be registered to show wide compliance buy-in. The declining increase is indeed troubling. Total global compliance remains less than 20% by both the IRS and foreign government estimated numbers.
The 30% FATCA withholding began July 1st on 143 countries (101 have IGAs that forestall withholding until January 1, 2015). Only 4,991 FFI (5%) registered from these 143 countries. Thus, FATCA compliance is running in the low, single digits for these countries. FATCA isn't gaining widespread acceptance - at least not yet.
free chapter download here —> http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2457671 Number of Pages in PDF File: 58
Most pundits thought at least 20% of the FFIs requiring FATCA registration would have done so by September - with only 120 days left before the precipice of 30% withholding begins against IGA countries. 120,000 is the minimum number brought up by industry for the September list that would need be registered to show wide compliance buy-in. The declining increase is indeed troubling. Total global compliance remains less than 20% by both the IRS and foreign government estimated numbers.
The 30% FATCA withholding began July 1st on 143 countries (101 have IGAs that forestall withholding until January 1, 2015). Only 4,991 FFI (5%) registered from these 143 countries. Thus, FATCA compliance is running in the low, single digits for these countries. FATCA isn't gaining widespread acceptance - at least not yet.
free chapter download here —> http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2457671 Number of Pages in PDF File: 58
| Model 1A IGA | 54,829 | 85 | Note 4 |
| Model 1B IGA | 22,779 | 3 | |
| Model 2 IGA | 16,524 | 13 | |
| US | 679 | 1 | |
| US Territory | 59 | 5 | Notes 1 |
| No IGA | 4,991 | 144 | Notes 2 |
| Total | 99,861 | 250 | Notes 1, 2, 3 & 4 |
| Non IGA | 4,991 | 144 | |
| Non IGA% | 5% | 58% | |
| IGA | 94,132 | 101 | |
| IGA% | 94% | 40% | |
| US and US Territories | 738 | 6 | |
| US % http://lawprofessors.typepad.com/intfinlaw/2014/09/fatca-ffi-update-and-it-doesnt-look-pretty-september-did-not-break-100000.html |
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