FACTA Calendar and Timelines
1- April 15, 2012. Individual reporting requirements of offshore assets begin subject to new IRS form 8938 on foreign financial assets held as of December 31, 2011. (Even though this is in the past, this is where I would start).
2- January 1, 2013. Original implementation date for foreign banks to report to IRS on their US customers. This deadline has been extended.
3- June 30, 2013. Deadline for foreign financial institutions (FFIs) to enter into agreement with IRS that they intend to comply with FATCA and begin reporting effective January 1, 2014.
4- January 1, 2014. Initial reporting goes into effect on all NEW accounts with compliant FFIs. Withholding tax begins on all non-compliant FFIs through US Federal Reserve banks as well as other compliant FFIs.
5- June 30, 2014. Due diligence and information disclosure must be in place on all compliant FFIs with regard to existing clients.
6- December 31, 2014. Specific reporting on "High Net Worth" (i.e. $500,000 or more) existing clients by FFIs to IRS begins.
7- December 31, 2015. Specific reporting on preexisting, non-high value clients begins.
8- January 1, 2017. Foreign "pass thru" withholding begins on foreign transactions, going from one foreign bank to another, passing through US banks, and going to non-compliant banks.
