This course provides an overview of the global anti-tax evasion regulation landscape, including an explanation of FATCA, QI and AEoI regulations. The course then discusses in detail the impact of GATCA, including the context and content of the various regulations and their effect on various types of financial institution.

Who Should Attend?

Senior staff at financial institutions who are keen to understand and plan for the development of tax transparency and evasion deterrence regulations


  • What is GATCA?
  • Avoidance, evasion and taxation: Scale and scope of the problem
  • US Internal Revenue Code Chapter 3: QIs and NQIs – an overview
  • US Internal Revenue Code Chapter 4: FATCA – an overview
  • OECD initiatives – an overview
    • AEoI/CRS
    • TRACE IP
Context and Structure
  • Structure
  • Definitions
  • Principles of non-duplicative taxation
  • How QI, FATCA and AEoI/CRS work
  • Effect on clients of financial institutions
Legal Basis
  • QI and FFI agreements
  • Data protection
  • Competent authority agreements
  • Domestic statute
  • Partner letters
A Strategic Overview of Practical Compliance Issues
  • Consequences of structural overlap
  • Variations in definitions that impact due diligence and reporting
  • Relationship management
  • Structural arrangements with counterparties
The FFI Agreement and GIINs
Due Diligence
  • Chapter 4 status and types of client
    • FFIs, NFFEs, Individuals
    • Certified and registered deemed compliance
Withholding Issues in FATCA
  • Form 8966, IDES and ICMM
  • Content variation by year
Control and Oversight
  • Responsible officers
  • Compliance programme requirements
  • Periodic reviews
  • Certifications of compliance, completion of due diligence and adequate controls
  • Materiality and notification of material failure
IRC Chapter 3
  • The QI agreement and QIEINs
  • Due diligence
    • W-8s, W-9s, KYC, AML
  • Withholding issues in Chapter 3
  • Tax returns and information reporting
    • The reporting cycle
    • 1042 and 1042-S
    • 945 and 1099-X
  • Due diligence
    • Investor self declarations
  • Reporting
    • Status of OECD participants in CRS
  • Control and oversight
Planning a Strategic Response to GATCA
  • Future proofing for overlap and differentials
  • Technology
  • Adaptive compliance programs
  • The GATCA Resource Library
  • Consulting and training resources


This course is offered on an in-house basis. Clients will be asked to provide some advance preparatory information which will then be used to customise the course materials so that the material is of more relevance to their situation.

This course can be delivered to a group of between 10 and 40 delegates over a period of either one or two days.

Two day courses cover the same content in more depth, with some additional material, exercises and workshops to help delegates absorb the content more effectively. There is also a greater amount of time allowed for questions, so delegates have the time to structure and ask questions that are relevant to their circumstances.


Please complete our booking form below and we will be in touch to discuss your requirements and to provide a quote.

Contact Us

+44 (0) 1252 413551

Tilsmere House
30 Mill Lane
GU46 7TN