William Byrnes' Tax, Wealth, and Risk Intelligence

William Byrnes (Texas A&M) tax & compliance articles

Is FATCA failing? Here is my reply. (Haydon Perryman)

Posted by William Byrnes on October 2, 2014

FATCA & CRS Training. Advice. Consultancy.

Is FATCA failing? A reply.

This is a question that can be asked given that only 104K of FFIs had registered on the IRS Portal by September 24, 2014.


When you compare 104K to the IRS estimate that between 400K and 600K need to register, 104K does indeed look small.

On the face of it that means there are a lot of Non Participating FFIs out there. A look at the regulations will tell us that withholding starts in 2014.

It is a fact that the regulations state that withholding starts in 2014. But let me ask a question: is that actually what happens in reality?

Withholding occurs on NP-FFI (Non Participating FFIs) and RAH (Recalcitrant Account Holders).

FATCA has been factored into on boarding. For those who doubt this, just try opening an account – you’ll soon find that there are questions in the onboarding process that address…

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