In response to the COVID-19 pandemic, the IRS has granted foreign financial institutions a number of extensions on Foreign Account Tax Compliance Act reporting obligations due in 2020.

First, the IRS granted any foreign financial institution with a FATCA compliance certification deadline of July 1, 2020, an automatic extension to December 15, 2020.  See FAQ 21.  No extension request must be filed in order to obtain this relief.

Second, the IRS granted an extension of time for any Reporting Model 2 FFI or Participating FFI to file their annual FATCA Report (Form 8966).  See FAQ 4. This deadline was extended from March 31, 2020, to July 15, 2020.  Form 8809-I, Application for Extension of Time to File FATCA Form 8966, was not be required for this extension.  This extension also applied to other entities, such as U.S. Withholding Agents and Direct Reporting NFFEs, that had a Form 8966 filing deadline of March 31, 2020.

Third, the IRS granted an extension of time for Model 1 IGA jurisdictions to provide their FATCA data for tax year 2019 to the U.S. Competent Authority. See FAQ 5. Model 1 IGA jurisdictions have until December 31, 2020, to provide their data, although a jurisdiction may send tax year 2019 data prior to that date.

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