FATCA & CRS Alert 2020-07

FATCA & CRS Alert 2020-07



Jean Kizito

Partner, Financial Services Tax

KPMG in Luxembourg


IRS updates FATCA registration system

On 29 September 2020, the IRS announced it has updated the Foreign Account Tax Compliance Act (FATCA) registration system.

The changes are summarized as follows:

  • Delete registration: A financial institution can no longer delete its registration once it’s initiated, submitted or incomplete. Along these same lines, a lead financial institution can no longer delete member registrations when in any of the aforementioned stages. However, after a registration has an approved status, a financial institution can cancel the registration.
  • Sponsored entity table (sponsoring entities only): A status date has been added to the sponsored entity table, and a display of effective date for terminated sponsored entities has been added.
  • Email address fields: There is an updated validation measure.

Reference: IRS transmittal message

As a reminder, the Luxembourg Tax Authorities require a FATCA return (and in the absence of reportable accounts, a FATCA "nil return") per year from each Luxembourg reporting financial institution registered with the IRS.

Also, a Luxembourg financial institution deregistered with the IRS is required to provide a return in relation to the year of its deregistration. Thus, Luxembourg financial institutions should review their FATCA status and registration requirements prior to year-end. This will help to avoid having to file in 2022 (with respect to 2021), if not otherwise required.


Jean Kizito
Associate Partner, Financial Services Tax
Tel.: +352 22 51 51 5492
E-mail: jean.kizito@kpmg.lu

Ulrike Menn
Tel.: +352 22 51 51 5538
E-mail: ulrike.menn@kpmg.lu

Any tax advice in this communication is not intended or written by KPMG to be used, and cannot be used, by a client or any other person or entity for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing, or recommending to another party any matters addressed herein.The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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