William Byrnes' Tax, Wealth, and Risk Intelligence

By William Byrnes and Haydon Perryman

The IRS published its August list of 95,239  FATCA registered FFIs, including entities that completed the registration process by July 25^th.  The increase has been disappointing to say the least.  Only 7,246 additional entities completed registration this past month, up from 87,993 in July.

89,718 FFIs (94%) are registered from the 101 IGA countries on the GIIN list.  Only 4,801 FFI (5%) registered from the 143 countries without an IGA for which FATCA withholding began July 1^st.

June GIINs 77,354 -> July GIINs 87,993 -> August GIINs 95,239 (7,246 increase)

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 now.  We were wrong.  I was personally thinking that 110,000 would be registered for the August 1^st FFI list.  The small increase of just 7,246 is troubling.  Total global compliance remains in the single digits 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 4,801 FFI (5%) registered from these 143 countries.  Thus, FATCA compliance is running in the low, single digits for these countries.

read our analysis and a country-by-country, and IGA, breakdown at International Financial Law Professor

Who We Are?

Haydon Perryman, FATCA Compliance expert of Strevus, and I have been undertaking (and publishing) the leading, same-day, analysis of the previous June 2^nd  and the July 1^st  of the FATCA FFI GIIN list by country, by IGA, by EAG, as well as exploring other interesting aspects of registered FFIs, and FATCA compliance documentation (e.g. W-8s and equivalent forms allowed by IGA). Haydon brings the practical side to bear having established the FATCA compliance system for Tier 1 UK institutions and Tier 1 EU ones, and I the academic side being the primary author of Lexis’ Guide to FATCA Compliance and an international tax professor.

free chapter download here —> http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2457671   Number of Pages in PDF File: 58

Over 600 pages of in-depth analysis of the practical compliance aspects of financial service business providing for exchange of information of information about foreign residents with their national competent authority or with the IRS (FATCA).