The IRS itself established this in a press release, the 2014-17 announcement (pdf , 34 K , 16 pp.), dated April 2nd, which also confirms that banks, intermediaries and financial institutions operating in states that have signed agreements with the American tax authorities (such as Italy), will not have to produce proof of registration in the register before January 1st 2015.
On January 10, Italy signed an intergovernmental agreement (IGA) with the United States to regulate the exchange of tax data between the two countries. This will allow government intermediaries to avoid signing individual agreements with the U.S. tax authorities, thus saving costs: the Italian tax authorities will send the information to the U.S. tax authorities.
In recent weeks Abi, with circular no. 1 of 14 January 2014 and Assofiduciaria, with circular COM_2014_017 of 6 March 2014, described the new features of the Foreign Account Tax Compliance Act (Fatca).
In the coming weeks, the Italian Government is called upon to issue the law ratifying the agreement and the implementing decrees.
The circulars explain, first of all, that the FATCA regulation requires Italian banks, intermediaries, and trust companies to register with the U.S. tax authorities and to submit periodic reports to the Revenue Agency.
Registration must be done, in any case, by the end of the year.
The timing, however, does not worry the intermediaries.
The obligation likely to have the greatest impact will, in fact, be the one requiring the bank or intermediary to adopt customer due diligence procedures.
A proper due diligence that will have to be conducted with different methods for the accounts of natural persons and legal entities and with greater in-depth analysis for those opened after June 30, 2014.
For accounts held by individuals with a balance or value greater than 50 dollars (approximately 40 euros) and less than or equal to 1 million dollars (approximately 800 euros), the Italian bank or intermediary must verify, by June 30, 2016, the existence of the so-called US Presumed Tax Residence Index of the account holder only through an electronic search of its records.
Evidence of tax residency includes: the account holder's US citizen or resident status, the account holder's place of birth in the US, a US residential or mailing address, and a power of attorney granted to a person with a US address. If one or more evidence is present, the Italian bank or intermediary may choose to report the account to the authorities as US or conduct further checks, including by consulting the customer.
For accounts over one million dollars, the Italian bank or intermediary will not be able to, but will instead be required to carry out a paper-based verification of any documentary evidence (for example, that collected for anti-money laundering purposes) relating to the previous five years.
The verification must be completed by June 30, 2015. For accounts opened after June 30, 2014, the Italian intermediary must obtain a self-certification from the client verifying their US residency or obtaining a certificate of residency or identity document. It will therefore be even more important to compare the information with that collected for anti-money laundering purposes to detect inconsistencies or the presence of the aforementioned US indicia, with the consequent application of the taxation applicable to US persons in the case of income derived from US securities.

by Fabrizio Vedana

Source: Italia Oggi
http://www.italiaoggi.it/giornali/preview_giornali.asp?id=1878559&codiciTestate=1&sez=hgiornali