26.03.2020
4'
Updated deadlines for filing the FATCA, QI and CRS reporting
On March 25, 2020 the IRS announced via Notice 2020-18 and a corresponding FAQ that in response to COVID-19, Reporting Model 2 FFIs and Participating FFIs will be granted with an extension of time to file their FATCA Reporting for tax year 2019.
FATCA Reporting
For the FATCA Reporting for tax year 2019, performed by Reporting Model 2 FFIs or Participating FFIs due on March 31, 2020, the filing deadline will be extended to July 15, 2020. This extension is automatic Reporting Model 2 FFIs and Participating FFIs will not be required to file Forms 8809-I to make use of this extension. Swiss Reporting Model 2 FFIs are therefore able to automatically benefit from the reporting relief and the July 15, 2020 deadline for filing the FATCA reporting.
For Reporting Model 1 FFIs required to file the FATCA Reporting to Model 1 tax authorities, the deadlines set by local authorities remain in force. For relief regarding any local deadlines for filing the FATCA Reporting, the respective local guidance should be considered.
Please note that there have not been any announcements regarding any possible FATCA Group Requests made to Swiss Reporting FFIs. Therefore, the preparation for the group requests should remain a high priority for FFIs that reported non-consenting U.S. account holders and NPFFIs in the past.
QI Reporting
The extension of the deadline for filing the 8966 reporting for tax year 2019, as well as the federal income tax return filing and payment relief announced in Notice 2020-18 do not extend to information returns such as the form 1042-S and form 1099 reporting.
Therefore, there have not been any changes in deadlines for the tax year 2019 QI reporting:
For filing forms 1042-S: March 16, 2020. For QIs that requested a 30-day extension by filing Form 8809, the deadline will be extended until April 16, 2020.
For filing forms 1042: March 16, 2020. For QIs that requested a 6-month extension by filing Form 7004, the deadline will be extended until September 16, 2020.
For filing forms 1099 electronically via FIRE: March 31, 2020. For QIs that requested a 30-day extension by filing Form 8809, April 30, 2020.
CRS Reporting
There have not been any announcements so far regarding the deadline for the tax year 2019 CRS reporting to the Swiss Federal Tax Authority (SFTA). The current deadline for filing CRS Reporting by Swiss Financial Institutions remains June 30, 2020.
For updates regarding the deadlines for filing the CRS Reporting in other jurisdictions, the local guidance should be considered.
For more information regarding the reporting requirements and deadlines for tax year 2019, please refer to Reporting Requirements 2020.
We continue to monitor the COVID-19 situation with respect to any changes in reporting requirements and will inform about them via this channel as soon as it is available.