FATCA Compliance

The provisions of FATCA are effective starting on July 1, 2014, which will require Altas Union to document and classify both US Persons and all entity accounts in order to report accounts owned or controlled by U.S taxpayers.

Account information is intended to be reported directly to the U.S. Internal Revenue Service (IRS), however, to address privacy and regulatory concerns related to FATCA, many Caribbean governments and the U.S. have signed an inter governmental agreement (IGA). FATCA partnering countries will implement laws to require financial institutions to collect and report the information required by FATCA directly to the local tax authority. Under the local legislation enacted in furtherance of the intergovernmental agreement, financial institutions are required to provide information relating to U.S. reportable accounts and payments made to non-participating foreign financial institutions (NPFFIs). This means that the information will be reported to the local authority, instead of directly to the IRS. Altas Union and its subsidiaries will meet all FATCA obligations, in accordance with local law.

FATCA applies to all Altas Union customers. Individuals who are US persons will be required to complete a W-9 form. In some cases, the bank may require non-US persons to certify their foreign (to the US) status with a W-8-BEN form.

Some Entity customers are required to Sign Up with the IRS and all must be classified for FATCA purposes. Customer documentation obligations are primarily driven by its classification as a U.S. withholding agent (USWA), foreign financial institution (FFI) or non-financial foreign entity (NFFE). For more information on registration for FATCA on the U.S. Internal Revenue Service (IRS) portal and list of entity classifications, refer to the IRS website.

In late 2014, Altas Union will request that some customers complete or provide either a W-8 form for non U.S. status or W-9 form for U.S. status.

The privacy of our clients is of the utmost importance to Altas Union. We are committed to keeping customers information, confidential, secure, and private. In complying with FATCA, we will adhere to applicable privacy laws while maintaining high standards of customer privacy and customer service at all times. The information presented above is provided only as an overview for informational purposes and is not intended to serve as legal or tax advice. For specific FATCA related questions, contact the IRS or your professional tax advisor.

View the appropriate W-8 forms here.

Altas Union is a participating foreign financial institution (PFFI) and has Sign Uped with the IRS. As such Altas Union will be requesting W-8/W-9 IRS tax forms from some customer in order to meet FATCA account due diligence, withholding and reporting requirements.

Account Due Diligence – Altas Union will:

• Collect and maintain certain documentation for some individual accounts
• Collect and maintain certain documentation for all entity client accounts
• Amend onboarding processes to capture the FATCA classification of new account holders
• Conduct a one-time remediation to collect documentation for FATCA classification of pre-existing account holders

Withholding – Altas Union will:

• Where applicable, identify payments derived from sources within the United States that are considered withholdable under FATCA
• Apply 30% tax on withholdable payments made to entity clients that are NPFFIs and do not qualify for a FATCA withholding exemption

Reporting – Altas Union will:

• Report annually on select information for U.S accounts and payments to non-participating FFIs to local competent authorities (typically a local taxation agency) starting 2015 (or subject to local law under the IGA)

As a participating FFI, Altas Union may refuse to conduct business with non-participating foreign financial institutions (NPFFI’s). Further, customers that do not provide requested documentation within the specified time will be deemed recalcitrant under FATCA regulations and will be considered reportable.