We hereby provide you with an overview of the reporting requirements for Swiss Financial Institutions (“SFI”) according to the FATCA and QI rules for the upcoming reporting for the tax year 2020 due in 2021.
The table below summarizes the relevant forms and deadlines for the 2020 QI and FATCA reporting to be filed in 2021:
|Forms||Deadline to report to the IRS
||Extension request possible?|
Non-consenting U.S. accounts
|31 January 2021||Electronically via IDES||No extension of time to file is permitted to report non-consenting U.S. accounts|
|1042||15 March 2021
(or 15 September 2021 if extension of time)
|Paper format||Yes, by completing Form 7004 until 15 March 2021 for an automatic 6-month extension of time|
|1042-S||15 March 2021
(or 14 April 2021 if extension of time)
|Electronically via FIRE||Yes, by completing Form 8809 until 15 March 2021 for an automatic 30-day extension of time|
Consenting U.S. accounts
|31 March 2021
(or 29 June 2021 if extension of time)
|Electronically via IDES||Yes, by completing Form 8809-I until 31 March 2021 for an automatic 90-day extension of time|
The 2020 forms and instructions are available on the IRS website.
As a reminder, compliance with Form 1042 and 1042-S reporting is one of the key areas of the IRS’ current enforcement and compliance initiatives. Many SFI have already experienced this, having received numerous and detailed follow-up queries on their QI reporting (especially variances in the 1042-S reconciliation) as part of the QI certifications filed by the Responsible Officer. We have also seen enforcement letters being sent by the IRS to SFI to explain and correct issues identified upon review of SFI’s annual Form 1042 and Form 1042-S reporting. Keeping that in mind, SFI should ensure that they have robust procedures and controls in place for their annual Form 1042 and Form 1042-S review, in particular for the Form 1042-S reconciliation, in order to avoid variances and follow-up action by the IRS.