What a difference a week makes! Since the announcement of the final regulations, it seems that every financial institution has just hit the accelerator button on their FATCA programmes. As a result, we’ve been powering through presentations and demonstrations on how our FATCA solutions work in practice.
As part of this, I’ve been giving more thought to the whole process behind self-certification and the role that banks play in this. The self-certification portion of the FATCA programme entails the provision of information through the completion of IRS-approved forms (e.g., W-9 and W-8BEN), along with the provision of additional documentation (depending on the indicia identified). For example, a person or entity:
· that is a U.S. citizen or permanent U.S. resident should complete a W-9
· who was born in the U.S. but resides elsewhere will be required to complete a W-9 or W-8BEN, provide documentary evidence in the form of non-U.S. passport (or other documentation establishing citizenship), along with a written submission renouncing U.S. citizenship.
· with a U.S. address (residence, correspondence or hold mail address e.g. U.S. PO Box) will need to complete either a W-9 or W-8BEN form, and provide documentary evidence in the form of non-U.S. passport or other similar documentation establishing citizenship