IRS releases new FATCA International Compliance Management Model (ICMM)

On 8 August 2015, the IRS issued an updated version of FATCA International Compliance Management Model (ICMM). The new ICMM validates record-level processing of FATCA 8966 XML files, including report files submitted before 8 August to correct two known errors regarding “Account Holder Type Not Valid” and “Pooled Reporting Type Not Populated”.

Based on the guidance, no response is required by the filer to the abovementioned error messages. The IRS will correct and send notifications for concerned files.

Additional information on this issue can be found under the “Q1” and “Q2” references of the “Field Level Errors” category of the Frequently Asked Questions (FAQs) (Link).

The Reserve Bank of India issues circular on FATCA Reporting requirements

On 28 August, the Reserve Bank of India (“RBI”), India’s Central Bank, issued a circular inviting financial institutions to comply with FATCA reporting requirements (Link). The circular includes clarifications on the date of enforcement of the IGA (31 August 2015), the identification of reportable accounts and the alternate procedure for their identification, the due diligence procedures, the treatment of new accounts (opened after 1 September 2015) and the control framework. The circular also states that a detailed guidance note is under preparation by the Central Board of Direct Taxes (“CBDT”).

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