US Foreign Account Tax Compliance Act (FATCA) FATCA and the Banking Sector
2nd CARIFORUM Conference on the
International Financial Services Sector in
the Caribbean Region
Ikins D Clarke
31October, 2012
Copyright © 2012 Deloitte & Touche. All rights reserved. 2
Today’s Agenda
Background
Draft FATCA Regulations
FATCA: Challenges to Banking
FATCA: Implementation Framework
Questions
Background
Copyright © 2012 Deloitte & Touche. All rights reserved. 4
IRS concern
• US persons escape their US tax obligations by holding assets through non-
US structures and products
IRS response
• Non-US financial institutions will be designated as Foreign Financial
Institutions, or “FFIs”
• The default position is that FFIs will suffer 30% withholding on all income &
sales proceeds from US sourced income
• Alternatively, FFIs can enter an agreement with the IRS and become
“participating FFIs”
Implications of non-compliance
• Financial, commercial and reputational risks
• May be forced to comply even where no US sourced payments exist as many
third parties are likely to require you to be FATCA compliant for practical
business reasons
Foreign Account Tax Compliance Act
What is FATCA?
Copyright © 2012 Deloitte & Touche. All rights reserved. 5
FATCA Overview
On February 8, 2012, the U.S. Treasury and IRS released the proposed regulations for
the Foreign Account Tax Compliance Act (FATCA) – Final regulations to be released by
the end of fall
Goal is to ensure U.S. persons with financial assets outside the U.S. are paying U.S. tax
U.S. Financial Institutions will have to withhold 30% on U.S. sourced payments to
foreign institutions/entities that do not comply – includes gross proceeds
In Summary
Who Needs to Comply?
U.S.
Withholding
Agents
U.S. entity that has control, receipt, custody disposal or payment of any withholdable
payment
Foreign
Financial
Institutions
(FFIs)
Non-U.S. entity that accepts deposits, holds financial assets for the account of others as a
substantial part of its business, or engages primarily in the business of investing or trading
securities, commodities, partnerships or any interests in such positions.
Non Financial
Foreign Entities
(NFFEs)
Includes any foreign entity that is not a FFI or is not one of the following specifically
EXCEPTED entities: Any publicly traded corporation and its corporate affiliates (more than 50% of vote and value)
Any entity organized under the laws of a possession of the U.S.
Any foreign government, or any wholly owned agency of
Any international organization or any wholly owned agency or instrumentality of such
Any foreign central bank (unless acting as intermediary for clients)
Any other class of persons identified by the Secretary as posing a low risk of tax evasion
U.S. Individuals U.S. Citizens, U.S. residents (e.g., Green card holder) and nonresident aliens who meet
the substantial presence test
Copyright © 2012 Deloitte & Touche. All rights reserved. 6
FATCA Timelines
2010 2011 2012 2013 2014
HIRE Act
passed Notice 2010-60 Notice 2011-34 Notice 2011-53
FATCA
effective date FFI Agreement
FFI withholding
phase-in begins
March 18, 2010
FATCA
provisions
passed into law
under HIRE Act.
September 13, 2010*
IRS initial guidance
describing the
requirements to
become a
participating FFI,
including
documentation due
diligence procedures
and reporting
requirements.
Released 8-27-2010
May 9, 2011*
Additional and
amended
guidance on
documentation of
pre-existing
accounts, pass-
thru payments
and reporting
requirements.
Date certification
by FFI
Responsible
Officer relates
back to.
Released 4-8-2011
January 1, 2013
Effective date of
FATCA
legislation.
February 8, 2012
Proposed FATCA
regulations. Draft
FFI Agreement
and certain other
matters
outstanding.
August 8, 2011*
Transitional relief
for FATCA
withholding on
payments to FFIs.
Released 7-14-2011 July 1, 2013
FFI Agreements
executed prior
to 6-30-2013
will have a 7-1-
2013 effective
date and will be
ensured to have
the assigned
FFI number
published in
time to prevent
FATCA FFI
withholding on
1-1-2014
(unless
otherwise
elected).
January 1, 2014
FATCA
withholding on
payments to FFIs
and NFFEs
begins on
Withholdable
Payments of
FDAP.
Fall 2012
Expected – Final
FATCA
regulations.
January 1, 2015
and beyond
FATCA
withholding on
payments to FFIs
and NFFEs:
Withholdable
Payments of
FDAP and gross
proceeds.
Pass-thru
Payments will
become subject to
FATCA
withholding.
Early 2013
Expected –
FFI
Agreements
ready to be
executed in
early 2013.
* Indicates date of official publication in the Internal Revenue Bulletin.
Copyright © 2012 Deloitte & Touche. All rights reserved. 7
FATCA Compliance Action Items 2013 2014 2015 2016 2017 2018
Gen
era
l
Co
mp
lian
ce
Grandfathered obligation
issuance/modification cutoff
Submit FATCA application to IRS
Transition period for affiliated group rule
On
bo
ard
ing
an
d
Rem
ed
iati
on
USWA begin new customer onboarding
Remediation – USWA
FFIs begin new customer onboarding
Remediation – FFI
Wit
hh
old
ing
Begin income withholding
Begin gross proceeds withholding
Begin foreign passthru payments
withholding
Rep
ort
ing
Begin account and balance reporting
Begin income reporting
Begin gross proceeds reporting
Announcement
2012-42 date
IRS Notice 2012-42 will extend certain deadlines from the proposed
FATCA regulations
Proposed
regulation date
Unchanged
Jan 1
Jan 1
Jan 1
Dec 31
Jan 1
Mar 31
Jan 1
Mar 15
Mar 15
Jan 1
Jan 1
Dec 31
Dec 31
Draft FATCA Regulations
Copyright © 2012 Deloitte & Touche. All rights reserved. 9
Due diligence
on
preexisting
accounts for
FFIs
Client
onboarding
for FFIs
Withholding
Preexisting account population requiring due diligence limited from prior
notice guidance:
• Preexisting individual account document review limited to accounts with over
US$1M balances
• Document search on high net worth accounts more defined (e.g., current
customer master file documents as opposed to “all available documents”).
• Preexisting entity accounts having balances under $250K are exempt from
review
Accounts on boarded after the FFI agreement subject to current
onboarding procedures used under AML/KYC except to the extent U.S.
indicia are identified.
• If U.S. indicia are determined as a part of the AML/KYC review, additional
documentation must be collected
• Certain entity accounts exempt from documenting substantial U.S. owners
• Short-term OID and ordinary course of business payments are excluded
• Grandfathering is extended
• Withholding phased in gradually between 2014 and 2017
Draft FATCA Regulations
Copyright © 2012 Deloitte & Touche. All rights reserved. 10
Reporting
Deemed
Compliant
Foreign
Entities
Miscellaneous
Expanded deemed-compliant categories
• Registered: Must certify it meets requirements every 3 years to IRS and inform
of any changes
• Certified: Certifies it meets requirements on Form W-8 to withholding agents
Other considerations of the proposed regulations concern:
• Definition of financial accounts for FFIs
• Affiliated group two-year transition for FFIs
• Compliance verification for FFIs
Similar to withholding, reporting will be phased in gradually between 2014
and 2017
Other highlights
• Reporting of payments made to non-participating FFIs and recalcitrant accounts
• Reporting does not need to be performed in U.S. currency
• Starting 2015, reporting is generally required to be filed on March 31
Draft FATCA Regulations (continued)
Copyright © 2012 Deloitte & Touche. All rights reserved. 11
Can We Believe Everything We Hear?
FATCA: Challenges to Banking FATCA’s Impact on the Banking industry
Copyright © 2012 Deloitte & Touche. All rights reserved. 13
FATCA – General Challenges
FATCA
Business
Operations
Technology Compliance
Tax
Tax provisions will
require interpretation
Foreign entities will need to be
classified at a much more
granular level, besides just
FFIs or NFFEs
The process for identifying
and documenting a foreign
entity’s status is still unclear,
and there is potential
exposure if the determination
is incorrect
Speed to market matters
Opportunity to either gain market share from or lose
market share to competitors
Rigorous communication and communication
strategy will be required for existing clients Operational processes
will need to be
augmented
Customer Facing: New Account
Processing, Account Transfers,
Client Reporting Statements,
Privacy and AML / KYC
Asset Servicing: Corporate
Actions Processing, Tax
Reporting, Security Master, and
Payments inventory & withholding
Regulatory Reporting: New
annual IRS/U.S. Treasury
Reporting
Technology investments will
need to be made
Potential new systems to continuously
track FFI agreements, as well as FFI
and NFFE ownership data
Existing systems and processes are
likely to struggle with the additional data
elements, withholding calculations and
reporting changes
Compliance will have to
be addressed across
countries
Compliance with FATCA’s due
diligence, verification and annual
reporting may result in conflicts
with local privacy laws
With presence in many countries,
institutions need to launch an
orchestrated compliance
monitoring effort to meet the
deadline
Copyright © 2012 Deloitte & Touche. All rights reserved. 14
FATCA – Banking Challenges
Customers
• Communication of changes to existing clients
• Managing the messaging and closure of recalcitrant accounts
• Proving that foreign accounts are, in fact, not U.S. accounts
• Monitoring account change of status, from non-U.S. to U.S., during the year
• Communication and disclosure related to waiver of secrecy rights
Systems
• Compiling customer and financial information from multiple systems for analysis
• Identifying and updating systems to be upgraded
• Assimilating and storing additional information provided by customers
• Updating systems to:
‒ Calculate pass-thru payment percentages and withholding exceptions
‒ Report account balance or value during the year
‒ Manage annual verifications of direct and indirect account ownership
Legal &
Compliance
• Identifying branches and affiliates to be included in FFI agreement
• Monitor compliance with the FFI agreement
• Update processes and manuals around account opening
• Assign a responsible officer to certify on-going compliance
• Managing potential conflicts with local secrecy laws
• Internal and external awareness programs
AML/KYC
• Expansion of current procedures to collect additional documentation:
‒ Identification of more than 10 percent ownership in any entity
‒ Identification of U.S. ownership for investment entities
Tax
• FATCA withholdings in addition to any current Qualifying Intermediary (QI) reporting
• Collecting the mandated five pieces of information per U.S. account
• Reporting the full Form 1099 on U.S. accounts instead of the annual filing
Copyright © 2012 Deloitte & Touche. All rights reserved. 15
FATCA Impacts – Banking Service Lines
Line of Business
Potential
FATCA
Impact
Rationale
Personal & Small Business Banking
• As a FFI, banks must enter into FFI Agreement(s) with the U.S. Treasury
• Banks will be responsible for performing due diligence on accounts and collecting
further documentation from accounts that have U.S. indicia
Retail & Commercial Banking
Business and Government Banking
Investment Banking
Pension Fund Administrator
• As a FFI engaged in pension fund administration, banks must enter into FFI
Agreement(s) with the U.S. Treasury, however certain deemed compliant or exempt
status may be applicable
• Banks will be responsible for performing due diligence on investors and collecting
further documentation from investors that have U.S. indicia
Mortgage Banking
• As a FFI engaged in mortgage lending, Banks must enter into FFI Agreement(s) with
the U.S. Treasury
• Banks will be responsible for performing due diligence on accounts and collecting
further documentation from accounts that have U.S. indicia
Copyright © 2012 Deloitte & Touche. All rights reserved. 16
FATCA Banking Impacts – Service Lines
Line of Business
Potential
FATCA
Impact
Rationale
Financing
• Finance companies are currently categorized as FFIs for investing in debt obligations
and may have to enter into FFI Agreement(s) with the U.S. Treasury
• Although they may be technically FFIs, they may have few or no financial accounts to
document, withhold, and/or report because of the definition of a financial account
under FATCA, however some accounts may be identified to the extent the entities
accept deposits
Renting
• The FATCA status of operating leasing operations are currently unknown but could
be categorized as FFIs to the extent activities can be categorized as finance leasing
and therefore treated as investing in debt obligations
• These companies must determine whether these operations hold financial accounts,
and therefore must enter FFI Agreement(s) with the U.S. Treasury
Leasing • Leasing companies may be FFIs to the extent its leasing activities can be
categorized as finance leasing and therefore treated as investing in debt obligations
under FATCA
FATCA: Implementation Framework
Copyright © 2012 Deloitte & Touche. All rights reserved. 18
FATCA Implementation Framework
3. Implementation 2. Solution
Development 1. Assessment
5. Governance, Communications and Program Management
Target Operating
Model
Business
Requirements
Systems
Architecture
Development
Gap Analysis
Compliance Strategy
FATCA Scoping Process Change
Implementation
Existing Customer
Remediation
Systems Change
Implementation
On
-go
ing
Co
mp
lian
ce
Identify high impact areas,
combine “like” entities to
simplify analysis and craft
compliance strategy
Design a compliance
blueprint that extends existing
capabilities and leverages
ongoing KYC/AML initiatives
Actively govern the implementation
to minimize costs, impact to
business operations and risks to
customers
Involve tax experts from assessment through
implementation to support the application of
FATCA requirements to business operations
Balance central oversight and
coordination with local execution of
FATCA projects
Ro
ad
map
Dev
elo
pm
en
t
Imp
lem
en
tati
on
Pla
nn
ing
4. Tax Interpretation
Copyright © 2012 Deloitte & Touche. All rights reserved. 19
―Establish the Team‖
Establish a governance structure that enables the right level of engagement with stakeholders and clearly defines roles
and responsibilities
―Simplify the Problem‖
Segregate the requirements into manageable components based on functionality impacted and consider simplifying strategies
―Sequence Delivery‖
Stage implementation delivery to achieve compliance in conjunction with regulatory phase in dates
―Don’t Reinvent the Wheel‖
Leverage established tools to accelerate execution
3 2 4
1
Successful Implementation: Common Principles
Copyright © 2012 Deloitte & Touche. All rights reserved. 20
Establish the team: Mobilize effectively
• FATCA implementation cuts
across areas of the
organization that are often
silo-ed
• Make a decision as to how to
structure the program –
business lead, corporate lead,
etc.
• It is essential to establish the
right tone at the top and
sponsorship
• Engage and educate at least
three core constituencies:
– Senior management
– Implementation team
– Key external
constituencies
• Tailor education to the needs
of the audience – don’t get
bogged down in trying to
become FATCA experts
• FATCA requires the
cooperation and integration of
stakeholders across multiple
functions (e.g., Business,
Operations, IT, Compliance,
Tax and AML/KYC)
• Identify owners from each
function who will be
responsible for the effort
Identify Key Sponsors and Owners
Educate Core Stakeholders
Establish Program Ownership and
Governance
FATCA Compliance Program
1
• Deploy execution
management framework
including:
– Roles and responsibilities
– Stakeholder reporting
content and frequency
– Decision rights and
escalation protocols
• Track and manage
dependencies, risks, issues,
and critical path milestones
• Formally define execution
scope and requirements for
scope changes
Build the Execution Framework
Copyright © 2012 Deloitte & Touche. All rights reserved. 21
Simplify the problem: Modularize requirements and gaps
2
Modularizing the requirements enables the segregation of the project into manageable streams
and the rapid identification of gaps by system and process.
Modularize the requirements
Onboarding
1. Customer classification and
taxonomy
2. Onboarding systems
enhancements
3. Onboarding process
changes
4. Manual Workarounds
Remediation
1. Individuals (FFIs)
2. Entities
3. Recalcitrant Accounts
Strategy
Withholding
1. Grandfathered Obligations
2. U.S. Source Income
Payments
3. U.S. Source Gross
Proceeds
4. Foreign Pass thru
Payments
Reporting
1. Accounts and Balances of
Substantial U.S. Owners
2. U.S. Source Income
Payments
3. U.S. Source Gross
Proceeds
FFI Program Control and Assurance
1. FFI IRS Certification 4. Controls Framework
2. FFI Responsible Officer Framework 5. Body of evidence
3. Annual FFI Certification
Simplify the problem
Standing
Instructions
Avoid the need to monitor for
standing instructions created
to the US by removing
capability or service to allow
standing instructions to the US
Legal Entity
Assessment
Avoid the time spent analyzing
the minutia of legal structures
of your group businesses by
grouping them around the far
fewer operational differences
Withholding
Reduce the complexity of
withholding calculations by
establishing fully segregated
funds between US and non
US investments
Remediation
Avoid expensive enhanced
review procedures by
remediating the structured
data of customers with more
than $1m invested
Withholding and reporting
Minimize the reporting burden and avoid elements of the withholding
problem by exiting relationships with recalcitrant or non-participating
customers, counterparties and service providers
Copyright © 2012 Deloitte Development LLC. All rights reserved. 22 Implementing FATCA: A Discussion with Barclays
Sequence Delivery: Drive delivery to achieve compliance deadlines 3
2015 and Beyond 2012 2014 2013
USWA New Customer Onboarding
FFI New Customer Onboarding
USWA Pre-Existing Account Remediation – Prima Facie FFIs and Other Foreign Entity Accounts
Grandfathered Obligations
Income Withholding and Depositing
Gross Proceeds Withholding and Depositing
USWA NFFE US Owners Reporting
USWA Income Reporting (2014)
USWA Gross Proceeds Reporting (2015)
ILLUSTRATIVE
FFI Agreement
High Value Accts.
Review
P.E. Acct, Rem.
Review
Aff. Grp. Compliance
New
Cu
sto
me
r
On
bo
ard
ing
Pre
-Ex
isti
ng
Ac
co
un
t
Rem
ed
iati
on
Wit
hh
old
ing
an
d D
ep
os
itin
g
Rep
ort
ing
F
FI S
pe
cif
ic
Re
qu
irem
en
ts
Today
FFI Pre-Existing Account Remediation – Prima Facie FFIs, High Value Accounts and Other In Scope Accounts
Indicates Regulatory Milestone
FFI US Owners First Time Reporting
FFI Income Reporting (2015)
FFI Gross Proceeds Reporting (2016)
Firms on the Path to Delivery Success
• Established distinct team structure for each stream
• Recognized that the implementation plan has to “fit” the deadlines
• Focused on critical path items immediately
• Plan to mobilize against each stream as required
Copyright © 2012 Deloitte & Touche. All rights reserved. 23
Don’t Reinvent the Wheel: Leverage tools to accelerate the process where
possible
4
• A one stop FATCA Educational and Knowledge Shop
• Real-time guidance
• A dynamic, web-based interface.
FATCA Education
Portal
• Easy to understand decision flows to identify FATCA requirements
• Detailed decision points with a trace to FATCA notice
• Detailed data, system and process requirements support
• No FATCA experience required
Already identified as U.S. persons* for
other U.S. tax purposes?
Does the electronically searchable information indicate that the entity
account holder is a U.S. entity?
Presumed Foreign Entity. Does the
entity’s name clearly indicate that the entity is an FFI?
Does an entity engage in an active trade or
business?
Request documentation of status within 12 mo. of FFI’s Agreement
effective date. Did the entity provide documentation of its status prior to one year after the date of
the FFI’s request?
Excepted NFFE
After request, did the entity provide its FFI EIN and certification of its participating FFI status within 9 months of FFI’s Agreement
Effective Date?
Did the entity provide documentation of its status prior to one year after the date of the
FFI’s request?
Participating FFI
Presumed U.S. Entity. Request documentation establishing that they are
not a U.S. person or specified U.S. persons within one year of the effective date of the
FFI Agreement.
Recalcitrant account
holders *1“Withholding and
Reporting required”
Obtained Forms W-9
U.S. Accounts
“Reporting required”
U.S. Entity. Obtained documentation
establishing that they are not specified U.S. persons.
Treat as other than a U.S. account
Did U.S. entities provide
documentation establishing that they are not specified U.S.
persons?
U.S. Accounts
“Reporting required”
Treat as other than a U.S.
account
*1: Any entity that has not presented documentation establishing that they are not U.S. persons or specified U.S. persons pr ior to the date that is one year after the date of the FFI’s request will be classified as a specified U.S. person and the account holder is treated as a recalcitrant account holder
until the FFI receives the required documentation of the entity’s status.
*2: During the interim period (i.e., prior to the time that the entity account holder is treated as a non-participating FFI), the entity account holder will be considered an excepted NFFE, and its account will be treated as other than a U.S. account, unless the entity is otherwise identified by the IRS on a
published list.
*3: An entity account holder that does not present documentation prior to the date that is one year after the date of the FFI’s request will be treated as
a non-participating FFI from such date until the date on which appropriate documentation is received from the entity account holder by the
participating FFI.
*4: If the participating FFI is unable to obtain the documentation required with respect to a specified U.S. person identifie d in (i), the account holder
will be treated as a recalcitrant account holder from the date that is two years after the date on which the FFI Agreement entered into effect until the date appropriate documentation is received from the account holder.
FFI Entity Accounts
YES
NO
NOYES
YES
NO
YES
YES
NO
NO
For accounts opened after the date on which the participating FFI’s FFI agreement enters into effect
an FFI must identify status of accounts using ALL
information collected by the FFI regardless of whether such information is available in
electronically searchable files.
NFFE
Is NFFE Excepted?
Non-Participating FFI
“Withholding &
Reporting required”
1471(f) ExemptedDeemed-Compliant FFIParticipating FFI
Non-Participating
FFI *3
“Withholding &
Reporting required”
NO
NO
Excepted NFFE *2Request documentation of status
within 12 mo. of FFI’s agreement
effective date.
YES
(i) Identify each individual, and each other specified U.S. person that has an interest in such
entity, and (ii) if a specified U.S. person is
identified in (i), treat the account as a U.S. account and obtain documentation with respect to each
such person prior to 2 years after the FFI’s
Agreement effective date.
Recalcitrant account
holders *4
“Withholding and
Reporting required”
Obtained Forms W-9
U.S. Accounts
“Reporting required”
Excepted NFFE
NOYES
YES
*“Persons” can include an individual, trust, estate,
partnership, association, company or corporation.
Grandfathered Obligations: Any obligation with a defined term issued on or
before March 18, 2012 that has not been materially modified after that date
will not be subject to withholding on payments under the obligation or gross
proceeds from the disposition of the obligation. This applies only to
instruments with a definitive expiration term, and does not include bank
demand deposit or savings deposit accounts or equities purchased (as they
have no expiration terms).
Obtained Forms W-8,
Foreign Entity
YES NODecision Trees
• Configurable electronic searches and efficient
categorization of customers
• Consistent categorization
• Prioritizes accounts for remediation
• Limited manual documentation searches
Customer
Classification
Engine
• Off-the-shelf case management workflow tool
• Streamlined customer contact and remediation
• Real-time tracking and reporting
• Detailed case history and status
Remediation
Control Database
(―RCD‖)
• Detailed data, system and process requirements support
• No FATCA experience required
• Traceable back to FATCA notice
• Help you develop onboarding processes and procedures, system
requirements, business requirements, and functional requirements.
Requirements
Matrices
• Determine the legal entities impacted by FATCA
• Assess the impact based on a consistent scoring rubric
• Identify data availability across functions of account opening, withholding,
depositing and reporting
Web-based Survey
Tool
Copyright © 2012 Deloitte & Touche. All rights reserved. 24
Deloitte FATCA Global Footprint
Brazil
South Africa
UAE
Italy
Spain
Russia UK
South Korea
Singapore
New Zealand
Japan
Argentina
Mexico
Belgium
Denmark
Finland
France
Ireland
Luxembourg
Netherlands
Norway
Poland
Portugal
Romania
Slovakia Germany
Czech
Republic
Switzerland
Uganda
United
States of
America
Canada
India
Australia
China
Caribbean:
Aruba &
Netherlands Antilles
Bahamas
Barbados
Bermuda
BVI
Cayman Islands
Dominican Republic
Jamaica
Trinidad & Tobago
Uruguay
Peru
Ecuador
Colombia
Panama Costa Rica
Nicaragua Honduras Guatemala
Chile
El Salvador
Blue dot denotes Deloitte FATCA global capability
Vietnam
Thailand
Malaysia
Taiwan
Sweden
Turkey
Iceland
Philippines
Guam
Pakistan
Indonesia Papua New Guinea
Brunei
Hong Kong
Estonia
Israel
Georgia
Cote d’Ivoire
Ghana
Greece
Jordan Cyprus
Bahrain
Lebanon
Serbia
Ukraine
Yemen
Tanzania
Cameroon
Nigeria
Austria
Senegal
Zambia Mauritius
Sydney
Melbourne
Primary offshore
centers:
Channel Islands
Isle of Man
Light blue dot denotes Natixis locations
Copyright © 2012 Deloitte & Touche. All rights reserved. 25
Your Deloitte Team — Engagement Leadership
Denise Hintzke
Director, Deloitte Tax LLP
New York
Ikins Clarke
Partner, Deloitte CBC
Barbados
Kristle Leigh Jeffers
Senior Manager, Deloitte CBC
Barbados
• Global Tax leader of Deloitte’s
FATCA initiative
• Denise works with the U.S. Tax
Information and Reporting practice
as well as the other Deloitte Touche
Tohmatsu Limited (“DTTL”) member
firms to deploy cross-functional
talent in response to the
requirements of the provisions of
U.S. FATCA
• Served as a managing director and
tax counsel at the Bank of New
York Mellon (BNYM), prior to
joining Deloitte Tax LLP
• Partner at Deloitte in Barbados and
has responsibility for Tax and
Corporate Advisory Services
• Ikins provides international tax
planning and corporate advisory
services to a range of international
clients - focusing on corporate
restructuring, corporate governance
and statutory compliance
• He heads the FATCA desk in the
Barbados office and leads the
Barbados initiative in providing
FATCA services to Barbados and
the Eastern Caribbean.
• Senior Manager at Deloitte in
Barbados works with clients in
Barbados and the Eastern
Caribbean with their understanding
FATCA regulations.
• Experience in IT controls reviews,
Compliance and Risk assessments,
and IT governance. Provide in-
depth analysis and leads projects
that call upon her ability and
expertise in sectors that include
banking, insurance, financial
services, manufacturing, retail,
energy, oil and gas.
Questions
About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Certain services may not be available to attest clients under the rules and regulations of public accounting.
Copyright © 2012 Deloitte & Touche. All rights reserved. 28
This presentation contains general information only and Deloitte is not, by means of this
presentation, rendering accounting, business, financial, investment, legal, tax, or other
professional advice or services. This presentation is not a substitute for such professional advice
or services, nor should it be used as a basis for any decision or action that may affect your
business. Before making any decision or taking any action that may affect your business, you
should consult a qualified professional advisor. Deloitte shall not be responsible for any loss
sustained by any person who relies on this presentation.
Top Related