FATCA Issues Additional Instructions Regarding Reporting on Form 1099

The IRS updated its instructions in a supplement to the 2014 general instructions to Form 1099.

In the instructions, the IRS explained that if a filer is required to report an account under IRS Code Chapter 4, the filer might be eligible to report the account on Form 1099 instead of Form 8966.

According to the instruction supplement, a filer is eligible to file Form 1099 if it is:

• a participating FFI ("PFFI"), deemed-compliant FFI (other than a Reporting Model 1 FFI) or a Registered Deemed-Compliant FFI ("RDC FFI") (other than a Reporting Model 1 FFI) that is required to report a U.S. account as a condition of its applicable RDC FFI status; and
• the account is a U.S. account held by a specified U.S. person that the filer elects to report under IRS Regulation 1.1471-4(d)(5)(i)(A) or 1.1471-4(d)(5)(i)(B).

See: FATCA Supplement to the 2014 General Instructions for Certain Information Returns Reporting on Forms 1099.See also: FATCA Specialty Page (available to Cabinet subscribers only). For more information, please contact Daniel Mulcahy or Mark Howe.