I am working on a FATCA project and was wonder under Canadian Law what is a general definition for "Responsible Officer"? Also could you provide a cite for the definition? Thanks
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John Stancil
The definition of a responsible officer is a United States definition, since it is a U. S. law. It is defined as an officer of any participating Foreign Financial Institution (FFI) that has sufficient authority to fulfill the requirements of the FATCA regulation and the FFI agreement. If the FFI is a part of a consolidated compliance program the RO must be an officer of the compliance financial institution.
So it is not defined by a title, but based on responsibilities. Anyone who is an officer of the institution could be the RO. He simply must be given the authority to fulfill the FATCA requirements.
www.irs.gov/Businesses/Corporations/Frequently-Asked-Questions-FAQs-FATCA--Compliance-Legal#Responsible
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512 weeks ago
So it is not defined by a title, but based on responsibilities. Anyone who is an officer of the institution could be the RO. He simply must be given the authority to fulfill the FATCA requirements.
www.irs.gov/Businesses/Corporations/Frequently-Asked-Questions-FAQs-FATCA--Compliance-Legal#Responsible