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FATCA – Position of Computershare Pending FurtherIRS Guidance Due Winter 2011› The Computershare global US tax team have been working with leadingtax advisers at a US-based international law firm. Together we havecreated a submission and sent it to the IRS to seek clarification on theclassification of ‘financial accounts’. Our submission can be reviewed athttp://www.bsmlegal.com/fatca-comments.asp› Should holdings on a share register and in an employee scheme beclassified as ‘financial accounts’ or not?› We would not view these as ‘financial accounts’ and therefore requestan exemption to FATCA rules› It is accepted, however, that as we undertake share custody, sharedealing and trust work we will become a participating FFI for at leastsome Computershare entities.14