This is a copy of an e-mail circulated by the Income Tax office

The first reporting, in respect of calendar year 2014 information for US Reportable Accounts, was 30 June 2015. This date has now elapsed and it may be that not all Financial Institutions have met their obligations in accordance with the Income Tax (Approved International Agreements) (Implementation) (United Kingdom and United States of America) Regulations, 2014, and therefore could be subject to penalties. As this is the first year of reporting, the Director is not intending to impose penalties immediately on Financial Institutions who appear not to have met their obligations yet, recognising that some Financial Institutions may have encountered unexpected issues which have led to a delay in submission. It is important, however, that any outstanding reports are now submitted promptly in order to avoid the imposition of penalties.

If any Financial Institution has already registered with IGOR, but has no reports to make for 2014 reporting, a simple ‘nil return’ is all that is required.

If a Financial Institution which has reports to make has not already registered on IGOR, or registered subsequent to 30 June 2015, they are urged to register and/or submit all 2014 reports within the next 7 days (i.e. by 8 July 2015). I would take the opportunity to clarify that there is only a requirement to register if it has been identified that reportable accounts are held.

If it is not possible for a Financial Institution to submit the 2014 report within the next 7 days (i.e. by 8 July 2015), they should use the correspondence facility in IGOR (Messages) immediately to send an explanation for this, and provide the date by which they expect to be able to do so, in order that the Director may consider the matter further.

Anyone requiring any further information concerning reporting obligations should refer to the published Guidance Notes.

Resources

Anyone having other technical issues relating to the submission of reports, should check the IGOR Forum and post questions if necessary.

A new tool has been created by Digimap in order to help technical personnel quickly understand the technical requirements of FATCA XML reporting. This is now available at https://fatcabuilder.digimap.gg/

Lee Harris
Compliance & International Manager
Income Tax Office, Treasury & Resources