August 2024 | Issue 14
Comply Connect
Designed to keep you informed on the latest IRS news and updates in information reporting, while also providing valuable insights into what’s on the horizon for the upcoming month.
Coming Up in September
Discover the U.S. information reporting and withholding obligations you should keep an eye on in the coming month.
Key Updates
Explore the Key updates provided by the IRS and other tax authorities from the last month you should be aware of.
FATCA & CRS Headlines
Take a look at our breakdown of the latest FATCA & CRS headlines to keep you up to date.
A message from our cEO:
This month has been a period of significant growth and progress for Comply Exchange. We’ve successfully launched two new clients, kicked off implementations and proof of concept projects with additional partners, and gone live with our new integrated app Copilot. These milestones highlight the trust our clients place in us and our commitment to continuous innovation.
We’re also proud of the strides we’ve made with our AI-driven WHS Extractor, setting a new standard in managing withholding statements. While others focus on standardization, we’re pushing boundaries with innovative approaches that truly benefit our clients.
On a personal note, my wife and I are looking forward to attending the wedding of our Director of Client Services, Jessica Metts—soon to be Metts Zeltser—in New York this week. It’s moments like these that remind me of the strong, supportive culture we’ve built at Comply Exchange—a culture that fuels our success.
Thank you for your ongoing support.
Coming up in September
IRS: Issue Number 2024-24 QI/WP/WT Application Deadline for 2024
On August 27, 2024, the IRS published Issue Number 2024-24 reminding taxpayers of the QI/WP/WT application deadline for 2024. All applicants that want to have an agreement in effect for 2024 must submit their applications through the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application & Account Management System (QAAMS) no later than September 30, 2024, to allow sufficient time for processing by year end.
If required for Chapter 4 purposes, applicants must have obtained a GIIN prior to submitting their applications.
Applications submitted after September 30, 2024, will not be processed. Applicants unable to submit an application before the September 30, 2024, deadline should wait until January 1, 2025, to submit the application for the 2025 year.
Panama: CRS Filing Deadline Extension
On August 2, 2024, the Panama tax authority announced that the deadline to submit CRS returns for the 2023 reporting period has been extended from July 31, 2024, until September 2, 2024.
August 2024 Key IRS Updates
IRS: Updated Draft Form 1099-DA
The IRS published Issue Number 2024-204 informing taxpayers of the release of an updated DRAFT 2025 Form 1099-DA, Digitial Asset Proceeds From Broker Transactions.
The new draft Form 1099-DA reflects the final regulations for custodial broker reporting. The forms will be sent separately to taxpayers and the IRS in early 2026. The IRS expects to post the draft instructions for filers soon. Once the draft filer instructions have been posted, a notice will be published in the Federal Register to allow for a 30-day comment period.
Interested parties can provide the IRS with comments about the draft at the forms and publications comments page on IRS.gov.
IRS: Issue Number 2024-21 New FAQs for QI/WP/WT
On August 1, 2024, the IRS published Issue Number 2024-21 notifying taxpayers of a new FAQ on the QI/WP/WT FAQs page. The IRS issued FAQ Q4 under the section, Provisions for 2023 QI Agreement. This FAQ extends the certification due date for a QI/WP/WT selecting the first or second year of the certification period for its periodic review or applying for a waiver of the periodic review from July 1st of the year following the certification to November 1st of the year following the certification period for the remainder of the term of the agreement.
Additionally, if a QI/WP/WT is selecting the third year of the certification period for its periodic review, the due date to select the periodic review year on QAAMS is extended until November 1st of the year following the certification period. The certification due date for a QI/WP/WT selecting the third year of the certification period for its periodic review will remain December 31st of the year following the certification period. However, according to previous Issue Number 2023-18, for a certification due in 2024 the due date for a QI/WP/WT selecting periodic review year 2023 is extended from December 31, 2024, to March 1, 2025.
The above extensions are automatic and do not require the filing of a request for extension with the IRS.
August 2024 FATCA & CRS Headlines
Ireland: Revenue eBrief No. 210/24
On August 6, 2024, the Office of the Revenue Commissioners in Ireland published eBrief No. 210/24 informing reporting financial institutions of updates to its AEOI guidance, Guide to Exchange of Information under Council Directive 2011/16/EU, Ireland’s Double Taxation Agreements and Tax Information Exchange Agreements and the OECD/Council of Europe Convention on Mutual Administrative Assistance in Tax Matters. The updates are as follows:
- Further information on the role of the Competent Authority in initiating the exchange of information has been added.
- References to Council Directive 2011/16/EU have been updated to reflect amendments to that Directive, including amendments under Council Directive (EU) 2021/514 (DAC7), as transposed by section 81 of Finance Act 2022 and S.l. 705/2022. These include the role of Platform Operators in section 3.8 and the purposes for which information exchanged may be used.
- The jurisdictions with which Ireland automatically exchanges information have been updated in Annex I.
Switzerland: Consultation on Determination of Partner States for the AEOI Concerning Cryptoassets
On August 14, 2024, the Federal Tax Administration (FTA) of Switzerland published a press release announcing the initiation of a consultation on the determination of partner states for the automatic exchange of information (AEOI) concerning cryptoassets. The Federal Council wants to use the bill to determine which of the 111 states and territories with which Switzerland has activated the AEOI, should automatically exchange information on cryptoassets from 2026, and which partner states could be implemented at a later date.
The consultation procedure will close on November 15, 2024.
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