Scope of FATCA regulations supported in CLM
CLM supports with questionnaires – one for entities and one for individuals – only the determination of the tax status of the customer, which is the steppingstone from which other FATCA requirements (for example, reporting) derive.
The questionnaires are prepared based on both the Model 1 and Model 2 IGAs, and they do not address any other U.S. tax obligations, specific IGAs or implementing legislation or the U.S. Treasury Department’s FATCA regulations. Therefore, should financial institutions need to ensure compliance with other relevant local laws and FATCA requirements, they will have to configure the questionnaires accordingly.
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