FATCA at Moodys Gartner Tax Law 1 | Page 22

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The due diligence requirements for pre-existing accounts differ depending on the value of the account as follows: (1) Accounts not exceeding us $50,000, cash value insurance or annuity contracts not exceeding us $250,000 on June 30, 2014, and cash value insurance or annuity contracts that cannot be effectively sold to us residents under Canadian or us law are not required to be reviewed, identified, or reported as us reportable accounts. (2) Lower-value accounts — those exceeding us $50,000 (US $250,000 for a cash value insurance contract or annuity contract) but not exceeding US $1 million — must be reviewed by an electronic record search for certain listed US indicia — facts indicating that the account holder is a US citizen or resident, such as a US place of birth or mailing address — by June 30, 2016, so that the reporting Canadian financial institution can ascertain whether the account holder is indeed a US person subject to FATCA (in which case, the institution must identify and report the holder’s US reportable accounts to the IRS). Notably, the electronic search is not required to identify all of the listed us indicia. If US indicia are not discovered, nothing further is required until there is a change in circumstances that results in the discovery of us indicia or the account becomes a high-value account.