A few days ago, the IRS and Department of Treasury invited the general public and other Federal agencies to comment on two new forms related to FATCA, by October 15, 2012. These forms are specifically for the banks or other Foreign Financial Institution (FFI), so it seems the banks must fall under the category of the general public.
The forms must be filled out and submitted by the RO, Responsible Officer, of the institution.
Form 8957 is the Registration for Participating, Limited, or Registered Deemed Compliant Foreign Financial Institution Status.
Form 8956 Application for Foreign Account Tax Compliance Act (FATCA) Individual Identification Number.
We talk about USA standing for the United States of Arrogance. This is particularly apt when one considers that the IRS (which is known for underestimation of time spent filling out forms), estimates that 260,000 institutions will have to fill out each of these forms.
Form 8956: Estimated number of respondents 260,000. Estimated time per Respondent: 2 hours, 59 minutes. Estimated total annual burden hours: 759,200
Form 8957: Estimated number of respondents: 260,000. Estimated time per Respondent: 8 hours, 7 minutes. Estimated total annual burden hours: 2,116,400.
I would think that for this kind of legal responsibility, the Reponsible Officer will be some sort of VP within the bank. What is the average salary of a high ranking bank official? Let’s take what I think would be a lowball guess at $150,000, and then rounded to about $200 per hour. According to the published estimates, then, a total of 2,875,600 hours will be required to register for FATCA. At $200 per hour, that’s $575,120,000.00 that will be spent filling out forms that benefit only the United States. Arrogance? I’d say so.
It will be interesting to see how many institutions send their comments, and what those might be.