by Kirsty Pitkin | Aug 23, 2016 | BlogPost
One of the most frequent excuses for NQIs not complying with reporting obligations, over and above lack of awareness, has always been the failure of the IRS to penalise firms for problems in filing. I thought the community should be aware that we are now starting to...
by Kirsty Pitkin | Nov 26, 2015 | BlogPost
FATCA Wars, Episode 2 – Attack of the Regs When we first came up with the idea of an ‘interim periodic review’ or IPR, we hoped it might generate a little interest. Well it did, in spades! We’ve now conducted a number of IPRs for clients in the UK, continental Europe...
by Kirsty Pitkin | Aug 26, 2015 | BlogPost
IPRs: The Story Continues… I started this blog series from the premise that FATCA has control and oversight mechanisms consisting of two parts: a continuing obligation on the responsible officer (RO) to declare any events of default or material failure of control...
by Kirsty Pitkin | Aug 14, 2015 | BlogPost
Three Things You Need To Know About An Interim Periodic Review (Part 2) So, in my last IPR blog I established why you might want to consider an interim periodic review (IPR) as part of your FATCA compliance program. The issue was and is about joining the dots between...