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Understanding FATCA Compliance at Bank of Ireland

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What is FATCA?

FATCA, or the Foreign Account Tax Compliance Act, is a law that requires financial institutions to report information about their non-US accounts held by US Persons or certain foreign entities to local tax authorities and the IRS.

FAQs on FATCA Compliance at Bank of Ireland

1. What does it mean if I’m a no-personal/entity customer?

You may be considered a Passive Non-Financial Entity (Passive NFFE), which is a type of entity that’s not classified as a financial institution but has one or more Specified US Persons holding at least 10% ownership interest.

2. What does it mean if I’m a foreign entity with controlling persons who are US Persons?

You may be considered a Passive Non-Financial Entity (Passive NFFE) if you have one or more controlling persons who are Specified US Persons, and this could make your account reportable under FATCA.

3. How will Bank of Ireland classify my customer status for FATCA purposes?

Bank of Ireland will use the self-certification form to determine whether an individual or entity is a U.S. Person or a non-U.S. person with respect to any account held by them at Bank of Ireland.

Types of Entities Considered US Persons

  • A citizen or resident of the United States
  • A foreign entity that is treated as a passive NFFE (if it has one or more Specified US Persons holding at least 10% ownership interest)
  • A corporation created in the United States or under the laws of any state in the United States
  • An estate or trust whose income is subject to tax in the United States, including certain trusts that are classified as Passive NFFEs

Documentation Required for FATCA Compliance

Bank of Ireland may request self-certification forms completed by customers who are U.S. Persons, or in relation to foreign entities where Bank of Ireland has identified one or more Specified US Persons as controlling persons.

7. Will I need to provide a self-certification form if I have already provided the required documentation?

If you have previously submitted FATCA information and it’s still current, you won’t be asked for another self-certification form. However, if your status changes or you update your account details, please notify Bank of Ireland.

Annual Certification

  • U.S. Person customers must complete a self-certification form on an annual basis.
  • Existing customers who have previously submitted FATCA information will be asked for a revised self-certification if their status has changed or details are no longer accurate.

Opening a New Account

You may need to provide the required documentation and complete a self-certification form, depending on your customer classification under FATCA.

Storing Completed Self-Certification Forms

Bank of Ireland will store the completed self-certification form in our system as evidence of your non-reportable status or determine your reportable status for FATCA purposes.