US Foreign Account Tax Compliance Act (FATCA) · PDF fileUS Foreign Account Tax Compliance Act (FATCA) FATCA and the Banking Sector ... Any foreign central bank (unless acting as intermediary

US Foreign Account Tax Compliance Act (FATCA) FATCA and the Banking Sector

2nd CARIFORUM Conference on the

International Financial Services Sector in

the Caribbean Region

Ikins D Clarke

31October, 2012

Copyright © 2012 Deloitte & Touche. All rights reserved. 2

Today’s Agenda

Background

Draft FATCA Regulations

FATCA: Challenges to Banking

FATCA: Implementation Framework

Questions

Background


IRS concern

• US persons escape their US tax obligations by holding assets through non-

US structures and products

IRS response

• Non-US financial institutions will be designated as Foreign Financial

Institutions, or “FFIs”

• The default position is that FFIs will suffer 30% withholding on all income &

sales proceeds from US sourced income

• Alternatively, FFIs can enter an agreement with the IRS and become

“participating FFIs”

Implications of non-compliance

• Financial, commercial and reputational risks

• May be forced to comply even where no US sourced payments exist as many

third parties are likely to require you to be FATCA compliant for practical

business reasons

Foreign Account Tax Compliance Act

What is FATCA?


FATCA Overview

On February 8, 2012, the U.S. Treasury and IRS released the proposed regulations for

the Foreign Account Tax Compliance Act (FATCA) – Final regulations to be released by

the end of fall

Goal is to ensure U.S. persons with financial assets outside the U.S. are paying U.S. tax

U.S. Financial Institutions will have to withhold 30% on U.S. sourced payments to

foreign institutions/entities that do not comply – includes gross proceeds

In Summary

Who Needs to Comply?

U.S.

Withholding

Agents

U.S. entity that has control, receipt, custody disposal or payment of any withholdable

payment

Foreign

Financial

Institutions

(FFIs)

Non-U.S. entity that accepts deposits, holds financial assets for the account of others as a

substantial part of its business, or engages primarily in the business of investing or trading

securities, commodities, partnerships or any interests in such positions.

Non Financial

Foreign Entities

(NFFEs)

Includes any foreign entity that is not a FFI or is not one of the following specifically

EXCEPTED entities: Any publicly traded corporation and its corporate affiliates (more than 50% of vote and value)

Any entity organized under the laws of a possession of the U.S.

Any foreign government, or any wholly owned agency of

Any international organization or any wholly owned agency or instrumentality of such

Any foreign central bank (unless acting as intermediary for clients)

Any other class of persons identified by the Secretary as posing a low risk of tax evasion

U.S. Individuals U.S. Citizens, U.S. residents (e.g., Green card holder) and nonresident aliens who meet

the substantial presence test


FATCA Timelines

2010 2011 2012 2013 2014

HIRE Act

passed Notice 2010-60 Notice 2011-34 Notice 2011-53

FATCA

effective date FFI Agreement

FFI withholding

phase-in begins

March 18, 2010

FATCA

provisions

passed into law

under HIRE Act.

September 13, 2010*

IRS initial guidance

describing the

requirements to

become a

participating FFI,

including

documentation due

diligence procedures

and reporting

requirements.

Released 8-27-2010

May 9, 2011*

Additional and

amended

guidance on

documentation of

pre-existing

accounts, pass-

thru payments

and reporting

requirements.

Date certification

by FFI

Responsible

Officer relates

back to.

Released 4-8-2011

January 1, 2013

Effective date of

FATCA

legislation.

February 8, 2012

Proposed FATCA

regulations. Draft

FFI Agreement

and certain other

matters

outstanding.

August 8, 2011*

Transitional relief

for FATCA

withholding on

payments to FFIs.

Released 7-14-2011 July 1, 2013

FFI Agreements

executed prior

to 6-30-2013

will have a 7-1-

2013 effective

date and will be

ensured to have

the assigned

FFI number

published in

time to prevent

FATCA FFI

withholding on

1-1-2014

(unless

otherwise

elected).

January 1, 2014

FATCA

withholding on

payments to FFIs

and NFFEs

begins on

Withholdable

Payments of

FDAP.

Fall 2012

Expected – Final

FATCA

regulations.

January 1, 2015

and beyond

FATCA

withholding on

payments to FFIs

and NFFEs:

Withholdable

Payments of

FDAP and gross

proceeds.

Pass-thru

Payments will

become subject to

FATCA

withholding.

Early 2013

Expected –

FFI

Agreements

ready to be

executed in

early 2013.

* Indicates date of official publication in the Internal Revenue Bulletin.


FATCA Compliance Action Items 2013 2014 2015 2016 2017 2018

Gen

era

l

Co

mp

lian

ce

Grandfathered obligation

issuance/modification cutoff

Submit FATCA application to IRS

Transition period for affiliated group rule

On

bo

ard

ing

an

d

Rem

ed

iati

on

USWA begin new customer onboarding

Remediation – USWA

FFIs begin new customer onboarding

Remediation – FFI

Wit

hh

old

ing

Begin income withholding

Begin gross proceeds withholding

Begin foreign passthru payments

withholding

Rep

ort

ing

Begin account and balance reporting

Begin income reporting

Begin gross proceeds reporting

Announcement

2012-42 date

IRS Notice 2012-42 will extend certain deadlines from the proposed

FATCA regulations

Proposed

regulation date

Unchanged

Jan 1

Jan 1

Jan 1

Dec 31

Jan 1

Mar 31

Jan 1

Mar 15

Mar 15

Jan 1

Jan 1

Dec 31

Dec 31



Due diligence

on

preexisting

accounts for

FFIs

Client

onboarding

for FFIs

Withholding

Preexisting account population requiring due diligence limited from prior

notice guidance:

• Preexisting individual account document review limited to accounts with over

US$1M balances

• Document search on high net worth accounts more defined (e.g., current

customer master file documents as opposed to “all available documents”).

• Preexisting entity accounts having balances under $250K are exempt from

review

Accounts on boarded after the FFI agreement subject to current

onboarding procedures used under AML/KYC except to the extent U.S.

indicia are identified.

• If U.S. indicia are determined as a part of the AML/KYC review, additional

documentation must be collected

• Certain entity accounts exempt from documenting substantial U.S. owners

• Short-term OID and ordinary course of business payments are excluded

• Grandfathering is extended

• Withholding phased in gradually between 2014 and 2017



Reporting

Deemed

Compliant

Foreign

Entities

Miscellaneous

Expanded deemed-compliant categories

• Registered: Must certify it meets requirements every 3 years to IRS and inform

of any changes

• Certified: Certifies it meets requirements on Form W-8 to withholding agents

Other considerations of the proposed regulations concern:

• Definition of financial accounts for FFIs

• Affiliated group two-year transition for FFIs

• Compliance verification for FFIs

Similar to withholding, reporting will be phased in gradually between 2014

and 2017

Other highlights

• Reporting of payments made to non-participating FFIs and recalcitrant accounts

• Reporting does not need to be performed in U.S. currency

• Starting 2015, reporting is generally required to be filed on March 31

Draft FATCA Regulations (continued)


Can We Believe Everything We Hear?

FATCA: Challenges to Banking FATCA’s Impact on the Banking industry


FATCA – General Challenges

FATCA

Business

Operations

Technology Compliance

Tax

Tax provisions will

require interpretation

Foreign entities will need to be

classified at a much more

granular level, besides just

FFIs or NFFEs

The process for identifying

and documenting a foreign

entity’s status is still unclear,

and there is potential

exposure if the determination

is incorrect

Speed to market matters

Opportunity to either gain market share from or lose

market share to competitors

Rigorous communication and communication

strategy will be required for existing clients Operational processes

will need to be

augmented

Customer Facing: New Account

Processing, Account Transfers,

Client Reporting Statements,

Privacy and AML / KYC

Asset Servicing: Corporate

Actions Processing, Tax

Reporting, Security Master, and

Payments inventory & withholding

Regulatory Reporting: New

annual IRS/U.S. Treasury

Reporting

Technology investments will

need to be made

Potential new systems to continuously

track FFI agreements, as well as FFI

and NFFE ownership data

Existing systems and processes are

likely to struggle with the additional data

elements, withholding calculations and

reporting changes

Compliance will have to

be addressed across

countries

Compliance with FATCA’s due

diligence, verification and annual

reporting may result in conflicts

with local privacy laws

With presence in many countries,

institutions need to launch an

orchestrated compliance

monitoring effort to meet the

deadline


FATCA – Banking Challenges

Customers

• Communication of changes to existing clients

• Managing the messaging and closure of recalcitrant accounts

• Proving that foreign accounts are, in fact, not U.S. accounts

• Monitoring account change of status, from non-U.S. to U.S., during the year

• Communication and disclosure related to waiver of secrecy rights

Systems

• Compiling customer and financial information from multiple systems for analysis

• Identifying and updating systems to be upgraded

• Assimilating and storing additional information provided by customers

• Updating systems to:

‒ Calculate pass-thru payment percentages and withholding exceptions

‒ Report account balance or value during the year

‒ Manage annual verifications of direct and indirect account ownership

Legal &

Compliance

• Identifying branches and affiliates to be included in FFI agreement

• Monitor compliance with the FFI agreement

• Update processes and manuals around account opening

• Assign a responsible officer to certify on-going compliance

• Managing potential conflicts with local secrecy laws

• Internal and external awareness programs

AML/KYC

• Expansion of current procedures to collect additional documentation:

‒ Identification of more than 10 percent ownership in any entity

‒ Identification of U.S. ownership for investment entities

Tax

• FATCA withholdings in addition to any current Qualifying Intermediary (QI) reporting

• Collecting the mandated five pieces of information per U.S. account

• Reporting the full Form 1099 on U.S. accounts instead of the annual filing


FATCA Impacts – Banking Service Lines

Line of Business

Potential

FATCA

Impact

Rationale

Personal & Small Business Banking

• As a FFI, banks must enter into FFI Agreement(s) with the U.S. Treasury

• Banks will be responsible for performing due diligence on accounts and collecting

further documentation from accounts that have U.S. indicia

Retail & Commercial Banking

Business and Government Banking

Investment Banking

Pension Fund Administrator

• As a FFI engaged in pension fund administration, banks must enter into FFI

Agreement(s) with the U.S. Treasury, however certain deemed compliant or exempt

status may be applicable

• Banks will be responsible for performing due diligence on investors and collecting

further documentation from investors that have U.S. indicia

Mortgage Banking

• As a FFI engaged in mortgage lending, Banks must enter into FFI Agreement(s) with

the U.S. Treasury

• Banks will be responsible for performing due diligence on accounts and collecting

further documentation from accounts that have U.S. indicia


FATCA Banking Impacts – Service Lines

Line of Business

Potential

FATCA

Impact

Rationale

Financing

• Finance companies are currently categorized as FFIs for investing in debt obligations

and may have to enter into FFI Agreement(s) with the U.S. Treasury

• Although they may be technically FFIs, they may have few or no financial accounts to

document, withhold, and/or report because of the definition of a financial account

under FATCA, however some accounts may be identified to the extent the entities

accept deposits

Renting

• The FATCA status of operating leasing operations are currently unknown but could

be categorized as FFIs to the extent activities can be categorized as finance leasing

and therefore treated as investing in debt obligations

• These companies must determine whether these operations hold financial accounts,

and therefore must enter FFI Agreement(s) with the U.S. Treasury

Leasing • Leasing companies may be FFIs to the extent its leasing activities can be

categorized as finance leasing and therefore treated as investing in debt obligations

under FATCA

FATCA: Implementation Framework


FATCA Implementation Framework

3. Implementation 2. Solution

Development 1. Assessment

5. Governance, Communications and Program Management

Target Operating

Model

Business

Requirements

Systems

Architecture

Development

Gap Analysis

Compliance Strategy

FATCA Scoping Process Change

Implementation

Existing Customer

Remediation

Systems Change

Implementation

On

-go

ing

Co

mp

lian

ce

Identify high impact areas,

combine “like” entities to

simplify analysis and craft

compliance strategy

Design a compliance

blueprint that extends existing

capabilities and leverages

ongoing KYC/AML initiatives

Actively govern the implementation

to minimize costs, impact to

business operations and risks to

customers

Involve tax experts from assessment through

implementation to support the application of

FATCA requirements to business operations

Balance central oversight and

coordination with local execution of

FATCA projects

Ro

ad

map

Dev

elo

pm

en

t

Imp

lem

en

tati

on

Pla

nn

ing

4. Tax Interpretation


―Establish the Team‖

Establish a governance structure that enables the right level of engagement with stakeholders and clearly defines roles

and responsibilities

―Simplify the Problem‖

Segregate the requirements into manageable components based on functionality impacted and consider simplifying strategies

―Sequence Delivery‖

Stage implementation delivery to achieve compliance in conjunction with regulatory phase in dates

―Don’t Reinvent the Wheel‖

Leverage established tools to accelerate execution

3 2 4

1

Successful Implementation: Common Principles


Establish the team: Mobilize effectively

• FATCA implementation cuts

across areas of the

organization that are often

silo-ed

• Make a decision as to how to

structure the program –

business lead, corporate lead,

etc.

• It is essential to establish the

right tone at the top and

sponsorship

• Engage and educate at least

three core constituencies:

– Senior management

– Implementation team

– Key external

constituencies

• Tailor education to the needs

of the audience – don’t get

bogged down in trying to

become FATCA experts

• FATCA requires the

cooperation and integration of

stakeholders across multiple

functions (e.g., Business,

Operations, IT, Compliance,

Tax and AML/KYC)

• Identify owners from each

function who will be

responsible for the effort

Identify Key Sponsors and Owners

Educate Core Stakeholders

Establish Program Ownership and

Governance

FATCA Compliance Program

1

• Deploy execution

management framework

including:

– Roles and responsibilities

– Stakeholder reporting

content and frequency

– Decision rights and

escalation protocols

• Track and manage

dependencies, risks, issues,

and critical path milestones

• Formally define execution

scope and requirements for

scope changes

Build the Execution Framework


Simplify the problem: Modularize requirements and gaps

2

Modularizing the requirements enables the segregation of the project into manageable streams

and the rapid identification of gaps by system and process.

Modularize the requirements

Onboarding

1. Customer classification and

taxonomy

2. Onboarding systems

enhancements

3. Onboarding process

changes

4. Manual Workarounds

Remediation

1. Individuals (FFIs)

2. Entities

3. Recalcitrant Accounts

Strategy

Withholding

1. Grandfathered Obligations

2. U.S. Source Income

Payments

3. U.S. Source Gross

Proceeds

4. Foreign Pass thru

Payments

Reporting

1. Accounts and Balances of

Substantial U.S. Owners

2. U.S. Source Income

Payments

3. U.S. Source Gross

Proceeds

FFI Program Control and Assurance

1. FFI IRS Certification 4. Controls Framework

2. FFI Responsible Officer Framework 5. Body of evidence

3. Annual FFI Certification

Simplify the problem

Standing

Instructions

Avoid the need to monitor for

standing instructions created

to the US by removing

capability or service to allow

standing instructions to the US

Legal Entity

Assessment

Avoid the time spent analyzing

the minutia of legal structures

of your group businesses by

grouping them around the far

fewer operational differences

Withholding

Reduce the complexity of

withholding calculations by

establishing fully segregated

funds between US and non

US investments

Remediation

Avoid expensive enhanced

review procedures by

remediating the structured

data of customers with more

than $1m invested

Withholding and reporting

Minimize the reporting burden and avoid elements of the withholding

problem by exiting relationships with recalcitrant or non-participating

customers, counterparties and service providers

Copyright © 2012 Deloitte Development LLC. All rights reserved. 22 Implementing FATCA: A Discussion with Barclays

Sequence Delivery: Drive delivery to achieve compliance deadlines 3

2015 and Beyond 2012 2014 2013

USWA New Customer Onboarding

FFI New Customer Onboarding

USWA Pre-Existing Account Remediation – Prima Facie FFIs and Other Foreign Entity Accounts

Grandfathered Obligations

Income Withholding and Depositing

Gross Proceeds Withholding and Depositing

USWA NFFE US Owners Reporting

USWA Income Reporting (2014)

USWA Gross Proceeds Reporting (2015)

ILLUSTRATIVE

FFI Agreement

High Value Accts.

Review

P.E. Acct, Rem.

Review

Aff. Grp. Compliance

New

Cu

sto

me

r

On

bo

ard

ing

Pre

-Ex

isti

ng

Ac

co

un

t

Rem

ed

iati

on

Wit

hh

old

ing

an

d D

ep

os

itin

g

Rep

ort

ing

F

FI S

pe

cif

ic

Re

qu

irem

en

ts

Today

FFI Pre-Existing Account Remediation – Prima Facie FFIs, High Value Accounts and Other In Scope Accounts

Indicates Regulatory Milestone

FFI US Owners First Time Reporting

FFI Income Reporting (2015)

FFI Gross Proceeds Reporting (2016)

Firms on the Path to Delivery Success

• Established distinct team structure for each stream

• Recognized that the implementation plan has to “fit” the deadlines

• Focused on critical path items immediately

• Plan to mobilize against each stream as required

http://eroom1.dc.com/eRoom/amin3/ProgramLeadershipMethod/0_b6d1


















Don’t Reinvent the Wheel: Leverage tools to accelerate the process where

possible

4

• A one stop FATCA Educational and Knowledge Shop

• Real-time guidance

• A dynamic, web-based interface.

FATCA Education

Portal

• Easy to understand decision flows to identify FATCA requirements

• Detailed decision points with a trace to FATCA notice

• Detailed data, system and process requirements support

• No FATCA experience required

Already identified as U.S. persons* for

other U.S. tax purposes?

Does the electronically searchable information indicate that the entity

account holder is a U.S. entity?

Presumed Foreign Entity. Does the

entity’s name clearly indicate that the entity is an FFI?

Does an entity engage in an active trade or

business?

Request documentation of status within 12 mo. of FFI’s Agreement

effective date. Did the entity provide documentation of its status prior to one year after the date of

the FFI’s request?

Excepted NFFE

After request, did the entity provide its FFI EIN and certification of its participating FFI status within 9 months of FFI’s Agreement

Effective Date?

Did the entity provide documentation of its status prior to one year after the date of the

FFI’s request?

Participating FFI

Presumed U.S. Entity. Request documentation establishing that they are

not a U.S. person or specified U.S. persons within one year of the effective date of the

FFI Agreement.

Recalcitrant account

holders *1“Withholding and

Reporting required”

Obtained Forms W-9

U.S. Accounts

“Reporting required”

U.S. Entity. Obtained documentation

establishing that they are not specified U.S. persons.

Treat as other than a U.S. account

Did U.S. entities provide

documentation establishing that they are not specified U.S.

persons?

U.S. Accounts


Treat as other than a U.S.

account

*1: Any entity that has not presented documentation establishing that they are not U.S. persons or specified U.S. persons pr ior to the date that is one year after the date of the FFI’s request will be classified as a specified U.S. person and the account holder is treated as a recalcitrant account holder

until the FFI receives the required documentation of the entity’s status.

*2: During the interim period (i.e., prior to the time that the entity account holder is treated as a non-participating FFI), the entity account holder will be considered an excepted NFFE, and its account will be treated as other than a U.S. account, unless the entity is otherwise identified by the IRS on a

published list.

*3: An entity account holder that does not present documentation prior to the date that is one year after the date of the FFI’s request will be treated as

a non-participating FFI from such date until the date on which appropriate documentation is received from the entity account holder by the

participating FFI.

*4: If the participating FFI is unable to obtain the documentation required with respect to a specified U.S. person identifie d in (i), the account holder

will be treated as a recalcitrant account holder from the date that is two years after the date on which the FFI Agreement entered into effect until the date appropriate documentation is received from the account holder.

FFI Entity Accounts

YES

NO

NOYES

YES

NO

YES

YES

NO

NO

For accounts opened after the date on which the participating FFI’s FFI agreement enters into effect

an FFI must identify status of accounts using ALL

information collected by the FFI regardless of whether such information is available in

electronically searchable files.

NFFE

Is NFFE Excepted?

Non-Participating FFI

“Withholding &


1471(f) ExemptedDeemed-Compliant FFIParticipating FFI

Non-Participating

FFI *3

“Withholding &


NO

NO

Excepted NFFE *2Request documentation of status

within 12 mo. of FFI’s agreement

effective date.

YES

(i) Identify each individual, and each other specified U.S. person that has an interest in such

entity, and (ii) if a specified U.S. person is

identified in (i), treat the account as a U.S. account and obtain documentation with respect to each

such person prior to 2 years after the FFI’s

Agreement effective date.

Recalcitrant account

holders *4

“Withholding and


Obtained Forms W-9

U.S. Accounts


Excepted NFFE

NOYES

YES

*“Persons” can include an individual, trust, estate,

partnership, association, company or corporation.

Grandfathered Obligations: Any obligation with a defined term issued on or

before March 18, 2012 that has not been materially modified after that date

will not be subject to withholding on payments under the obligation or gross

proceeds from the disposition of the obligation. This applies only to

instruments with a definitive expiration term, and does not include bank

demand deposit or savings deposit accounts or equities purchased (as they

have no expiration terms).

Obtained Forms W-8,

Foreign Entity

YES NODecision Trees

• Configurable electronic searches and efficient

categorization of customers

• Consistent categorization

• Prioritizes accounts for remediation

• Limited manual documentation searches

Customer

Classification

Engine

• Off-the-shelf case management workflow tool

• Streamlined customer contact and remediation

• Real-time tracking and reporting

• Detailed case history and status

Remediation

Control Database

(―RCD‖)

• Detailed data, system and process requirements support

• No FATCA experience required

• Traceable back to FATCA notice

• Help you develop onboarding processes and procedures, system

requirements, business requirements, and functional requirements.

Requirements

Matrices

• Determine the legal entities impacted by FATCA

• Assess the impact based on a consistent scoring rubric

• Identify data availability across functions of account opening, withholding,

depositing and reporting

Web-based Survey

Tool


Deloitte FATCA Global Footprint

Brazil

South Africa

UAE

Italy

Spain

Russia UK

South Korea

Singapore

New Zealand

Japan

Argentina

Mexico

Belgium

Denmark

Finland

France

Ireland

Luxembourg

Netherlands

Norway

Poland

Portugal

Romania

Slovakia Germany

Czech

Republic

Switzerland

Uganda

United

States of

America

Canada

India

Australia

China

Caribbean:

Aruba &

Netherlands Antilles

Bahamas

Barbados

Bermuda

BVI

Cayman Islands

Dominican Republic

Jamaica

Trinidad & Tobago

Uruguay

Peru

Ecuador

Colombia

Panama Costa Rica

Nicaragua Honduras Guatemala

Chile

El Salvador

Blue dot denotes Deloitte FATCA global capability

Vietnam

Thailand

Malaysia

Taiwan

Sweden

Turkey

Iceland

Philippines

Guam

Pakistan

Indonesia Papua New Guinea

Brunei

Hong Kong

Estonia

Israel

Georgia

Cote d’Ivoire

Ghana

Greece

Jordan Cyprus

Bahrain

Lebanon

Serbia

Ukraine

Yemen

Tanzania

Cameroon

Nigeria

Austria

Senegal

Zambia Mauritius

Sydney

Melbourne

Primary offshore

centers:

Channel Islands

Isle of Man

Light blue dot denotes Natixis locations


Your Deloitte Team — Engagement Leadership

Denise Hintzke

Director, Deloitte Tax LLP

New York

Ikins Clarke

Partner, Deloitte CBC

Barbados

Kristle Leigh Jeffers

Senior Manager, Deloitte CBC

Barbados

• Global Tax leader of Deloitte’s

FATCA initiative

• Denise works with the U.S. Tax

Information and Reporting practice

as well as the other Deloitte Touche

Tohmatsu Limited (“DTTL”) member

firms to deploy cross-functional

talent in response to the

requirements of the provisions of

U.S. FATCA

• Served as a managing director and

tax counsel at the Bank of New

York Mellon (BNYM), prior to

joining Deloitte Tax LLP

• Partner at Deloitte in Barbados and

has responsibility for Tax and

Corporate Advisory Services

• Ikins provides international tax

planning and corporate advisory

services to a range of international

clients - focusing on corporate

restructuring, corporate governance

and statutory compliance

• He heads the FATCA desk in the

Barbados office and leads the

Barbados initiative in providing

FATCA services to Barbados and

the Eastern Caribbean.

• Senior Manager at Deloitte in

Barbados works with clients in

Barbados and the Eastern

Caribbean with their understanding

FATCA regulations.

• Experience in IT controls reviews,

Compliance and Risk assessments,

and IT governance. Provide in-

depth analysis and leads projects

that call upon her ability and

expertise in sectors that include

banking, insurance, financial

services, manufacturing, retail,

energy, oil and gas.

Questions

About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Certain services may not be available to attest clients under the rules and regulations of public accounting.


This presentation contains general information only and Deloitte is not, by means of this

presentation, rendering accounting, business, financial, investment, legal, tax, or other

professional advice or services. This presentation is not a substitute for such professional advice

or services, nor should it be used as a basis for any decision or action that may affect your

business. Before making any decision or taking any action that may affect your business, you

should consult a qualified professional advisor. Deloitte shall not be responsible for any loss

sustained by any person who relies on this presentation.

Documents

US Foreign Account Tax Compliance Act (FATCA) · PDF fileUS Foreign Account Tax Compliance Act (FATCA) FATCA and the Banking Sector ... Any foreign central bank (unless acting as intermediary