This is an excerpt from the strategic decisions tool. The strategic decisions a company has to take with regards to FATCA include the following questions, amongst others, if the company wants:
- to apply the “de-minimis” rule;
- to continue doing business with US persons;
to centrally organize the identification of all FFI’s in it’s group instead of delegating such activities to it’s affiliates;
to continue doing business with ‘Non Participating FFI’s.
The template below has proven to be very effective to obtain the necessary decisions.
Exhibit 5: Template and example of strategic decisions