International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Friday, August 28, 2015

New Release of the Foreign Account Tax Compliance Act (FATCA) International Compliance Management Model (ICMM)

The Internal Revenue Service (IRS) deployed an updated version of FATCA ICMM on August 8, FATCA_roll2015. The updated release validates record-level processing of FATCA 8966 XML Report files, including files that were submitted before August 8, 2015.  The record level processing identified errors within the files and issued new notifications to filers that reflect the outcomes of the validation.  The IRS discovered an issue related to the processing of files submitted between January 12th and August 8th of 2015 that resulted in two erroneous field level error messages.  These are as follows:

• “Account Holder Type Not Valid” error for an individual filer for whom an entity type is not required. This is for Account Reports in which the account holder is an “Individual”. 

• “Pooled Reporting Type Not Populated” error.  The issue applied to Pooled Reports.

The two error messages referenced do not require a response or correction by the filer in the situations described above.  The IRS is correcting this issue and will resend notifications for files that are impacted.  For additional information regarding these two field-level error messages please refer to “Q1” and “Q2” under the “Field Level Errors” category of the Frequently Asked Questions (FAQs).

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