To be compliant with the Foreign Account Tax Compliance Act (FATCA) of the United States, foreign (non-US) financial institutions (FFIs) have a window to register online with the US Internal Revenue Service between July 15'and October 25, 2013. However,'the question of whether or not to register remains the critical first decision that firms must get right .'This decision involves weighing the costs of either exiting the US markets and closing US customer accounts, or preparing and maintaining a business for ongoing FATCA compliance.

If FFIs want to control cost and manage regulatory risk, they must be willing to dedicate significant resources to the initial exercise of identifying which entities must be registered, rather than assuming that registering every entity is the best path forward. In our view, there are presently five considerations that FFIs should have on their 'to-do' list, to inform this calculation and outline next steps: 1. Registration preparation 2. Cleansing and handling client data 3. Establishing a client communication plan 4. Evaluating the provision or use of third-party services 5. Accommodating multiple and varied intergovernmental agreements (IGAs)... Read full story on Wall Street & Technology


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