As we discussed in a prior Herrick tax alert, 2014 will see the
implementation of a significant number of new tax compliance
requirements, including those under the "FATCA" (Foreign
Account Tax Compliance Act).1 One of the key FATCA
milestones is the registration with the IRS to obtain a
"global intermediary identification number"
("GIIN").
May 5, 2014, is the last day to finalize registration with the
IRS and obtain the GIIN and be included on the first IRS FFI
(Foreign Financial Institution) List (expected to come out on June
2, 2014).
If you are a foreign investor (other than an individual), you
will need to consider whether you have to obtain a GIIN. If you are
required to obtain a GIIN but fail to do so by today, you could be
subject to FATCA withholding on U.S.-source investment income, such
as interest and dividends, beginning on July 1, 2014.
