US Withholding Tax Chapter 4: FATCA


The course gives a detailed explanation of the regulations and the key process elements – due diligence, withholding, reporting and control and oversight. Responsibilities of Responsible Officers and Periodic Reviews are discussed, along with the application of due diligence rules both inside and outside IGA markets.

How do you know if your client is an American? ‘Reason to Know’ and ‘Actual Knowledge’ rules are explained and there is discussion and explanation of the IDES and ICMM systems and XML tools for processing FATCA reports. Significant time is spent discussing and explaining the practical experience of client on-boarding and handling client relationships, including how to comply without annoying your customers. Systems strategy is also covered. What data need to be collected, when and why, together with strategic discussion of integration and future-proofing for the global CRS model (‘GATCA’) are included, together with reflections about whether these rules present a problem or an opportunity and discussion of how various firms have approached FATCA and created opportunities from it.

Who Should Attend?

This course is designed for all FFIs and NFFEs that are affected by FATCA, including those both in and outside or EAGs.

It is also useful for High Net Worth and Ultra High Net Worth individuals and their advisors and asset managers.


  1. Introduction
  2. History & Context
  3. FATCA Framework
    1. FATCA obligations for Americans
    2. Legal Frameworks for Financial Institutions
      1. Definitions – the language of FATCA
      2. IGA Jurisdictions (Model 1, 2, and “in substance” variants)
      3. Non-IGA jurisdictions (the FFI Agreement)
      4. Expanded Affiliate Groups (“EAGs”)
      5. Consolidated Compliance Programs (“CCPs”)
  4. FATCA Operating Framework
    1. Documentation
    2. Due Diligence
    3. Reporting
      1. Delivery routes
      2. Data formats
  5. FATCA Governance Framework
    1. Competent Authorities
    2. Non-Compliance
      1. Substantial non-compliance
      2. Administrative Errors
    3. Enforcement
  6. FATCA Issues and FAQs
    1. Accidental Americans
    2. Current legal and political issues


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