A good question but not one that I am able to answer easily. At Boston we are prepared but do not under estimate the task ahead. In broad terms, preparation is geared towards two areas of FATCA, registration and reporting.

The first deadline is now past

For registration purposes, matters became a little clearer with the first deadline in April for non-Model 1 IGA jurisdictions. Whilst this task was on a much smaller scale than the next round of registrations there should be less to fear for those who have now experienced the process. Statistics show 313 Isle of Man entities now registered with the IRS which sounds low compared to, say, Guernsey, standing at 2,406. There will be a number of valid reasons contributing to this difference but I also suspect that some local businesses are not yet aligned with what is required of them.

Reporting starts 1st July 2014

Whilst firms may bemoan the associated costs of registration, this is likely to be minimal in comparison to the reporting aspects of FATCA, applicable from 1 July. In addition, new client on-boarding procedures also have to be implemented by this date. Firms have to be system ready now in order to capture all relevant data required for identification, monitoring and reporting purposes. If this process has not yet begun businesses will be on the back foot when the first reports have to be submitted in 2015.

Non-compliance is not an option

Some local businesses may need to refocus their efforts to avoid falling foul of the numerous pitfalls presented by FATCA which is something the Isle of Man as a whole needs to be aware of to insure against the risks of non-compliance.

More information on FATCA (including timetable and thoughts on how it will progress).