The first annual return is due to be filed by each reporting Irish financial institution (including a reporting fund) by no later than 30 June 2015. This return will be in respect of 2014. Revenue guidance indicates the mandatory format of the return is available on the IRS website and returns in other formats will not be accepted. Returns are to be filed with the Revenue Commissioners through its online system (ROS).
Broadly, the information required on all US reportable accounts are:
- the name, address and US tax identification number (TIN) of each US person that is an account holder and, in the case of a non-US entity account holder that has one or more controlling persons that is a US person the name, address and US TIN (if any) of such entity and each such US person,
- the account number (or its functional equivalent in the absence of an account number),
- the name and identifying number of the reporting fund, and
- the account balance or value as of the end of the reporting period.
To the extent that a reporting fund has no US reportable accounts it is still required to file a nil return. This is notwithstanding the fact that a recent change in approach in the US means the US requirement for the tax authorities of an IGA country (which would include the Revenue Commissioners in Ireland) to submit nil returns has been dropped.