The FATCA came into force on July 1, 2014, but its implementation was made gradually. In this sense, the first report of the US Accounts and Recalcitrant Accounts was made up to March 31, 2015 (referring to the year 2014) and should contain the following information: name, address, TIN, number and account balance of the US Persons (or, if the account has been closed after the entry into force of the FFI agreement, the amount withdrawn or transferred therefrom); the name, number and account balance of the Passive NFFEs with substantial US owners, as well as the name, address and TIN of each of the substantial US owners; the amount and aggregate number of recalcitrand accounts.

The second report, referring to the year 2015, should have been made until March 31, 2016. In addition to the information above, the second report should include the gross amount of interest, dividends and other income credited to each US account, except for gross proceeds. Information on the latter should be included in the third report.

Payments of non-US origin paid to nonparticipating foreign financial entities should only be made in 2016 and 2017, by reference to the years, until March 15.

Finally, US FDAP (US source fixed, determinable, annual, periodical payments) paid to recalcitrant accounts and non-participating FFIS (foreign financial entities) and their withheld tax, began to be reported in 2015, and by March 15, for reference to the previous year, whereas the US gross proceeds and their withholding tax will only have to be reported from 2018, by reference to 2017, since it is only this year that the withholding tax on these income begins.

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