Critical Issues on Opening Nonresident Alien Accounts: W-8BEN, CIP and CDD

In 2010, Congress passed the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147 (the HIRE Act), which added chapter 4 of Subtitle A to the Code, consisting of sections 1471 through 1474 of the Code and commonly referred to as “FATCA” or “chapter 4.” Form W-8BEN has been divided into two versions — Form W-8BEN for use by individuals and Form W-8BEN-E for use by entities. Form W-8BEN will continue to be used to document nonresident alien individuals, while Form W-8BEN-E will be used to document foreign entities, for purposes of chapters 3 and 4, and under certain other sections of the Code in order to establish their status for withholding or reporting purposes.

During this program we will examine the impact of FATCA, the new forms and 1042S reporting to the IRS. We will also look at acceptable forms of identification and Bank Secrecy Act issues in your Customer Identification Programs and due diligence. 

What You Will Learn

  • Who is a nonresident alien?
  • How FATCA impacted your account opening procedures?
  • Types of Identification to open account
  • CIP and CDD for Nonresident aliens
  • How to complete new W-8BEN and W-8BENE
  • New ITIN rules for expiration
  • Rules for using previous versions of the form
  • TIN requirements for Forms W-8BEN
  • Due Diligence requirements for withholding and "Reason to know"
  • Requesting a new W-8BEN
  • W-8 Period of Validity
  • Substitute Forms W-8
  • OFAC Special Issues

    Who Should Attend?

    This webinar will benefit tellers, new member representatives, branch managers, branch operations, compliance, training and all front line personnel.