News & Analysis as of

IRS Offers FATCA Relief, Extending Registration Deadline and Expanding Intergovernmental Agreement List

On April 2, 2014, the U.S. Internal Revenue Service (IRS) issued Announcement 2014-17 (the Announcement), which provides certain FATCA relief. The Announcement extends from April 25, 2014 to May 5, 2014 the deadline by which...more

FATCA: Crunch Time (April 25th Deadline is Imminent)

Every foreign entity must take steps immediately to determine whether FATCA will apply to it and, if so, whether FATCA registration will be required by April 25, 2014....more

FATCA regulations updated but deadlines loom

The US Department of the Treasury and the Internal Revenue Service have released what they refer to as the “last substantial package of regulations” necessary to implement the Foreign Account Tax Compliance Act (FATCA). ...more

FATCA: With Deadlines Looming, the Time to Act is Now

On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more

"Treasury and IRS Move to Implement FATCA as 2014 Start Date Approaches"

On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010 as part of...more

Treasury Delays FATCA Deadlines by Six Months

On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more

FATCA Alert: US announces six month postponement to the implementation dates for FATCA - the impact on UK FIs

On 12 July, just one working day before the secure portal to be used by FFIs to register their status was due to go live, the US Internal Revenue Service ("IRS") issued Notice 2013-43 ("the Notice") announcing the delay to...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43, released on July 12, 2013, announces the Internal Revenue Service’s (the IRS) and the Department of the Treasury’s intent to amend final Treasury regulations implementing the U.S. Foreign Account Tax...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43 (http://www.irs.gov/pub/irs-drop/n-13-43.pdf), released on July 12, 2013, announces the Internal Revenue Service's (the "IRS") and the Department of the Treasury's intent to amend final Treasury regulations...more

IRS Postpones Key FATCA Deadlines by Six Months; Updated Ropes & Gray FATCA Timeline Attached

On July 12, 2013, the Internal Revenue Service ("IRS") issued Notice 2013-43 (the "Notice"), postponing a number of deadlines under the Foreign Account Tax Compliance Act ("FATCA"). In the Notice, the IRS made a number of...more

Extension of FATCA Withholding Start Date and Grandfathering End Date

On July 12, Treasury and the IRS announced that they intend to amend final Treasury regulations implementing the U.S. Foreign Account Tax Compliance Act (FATCA) to provide for a six-month extension to the start of FATCA...more

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

FATCA Deadlines Extended

On July 12, 2013, the U.S. Internal Revenue Service (IRS) issued Notice 2013-43 (Notice) which extends certain key deadlines for implementing FATCA, and provides guidance regarding the effect of these deadlines on FATCA...more

IRS Delays Implementation of FATCA Tax Reporting Rules

The Internal Revenue Service this week released Announcement 2012-42 (the Announcement), which postpones until 2014 the need for foreign hedge funds and private equity funds to request Foreign Account Tax Compliance Act...more

BVI & Cayman Funds Round-Up: From FATCA to Fund Directors

Legislative Update - In the BVI, the BVI Business Companies Act has been amended to take into account a number of improvements and enhancements and to address a number of proposals that BVI practitioners had...more

Revisions to FATCA Implementation

IRS announces certain new time lines for implementation and further interpretive guidance. On October 24, the Internal Revenue Service (IRS) announced several key revisions to Foreign Account Tax Compliance Act...more

IRS Announces Extended FATCA Deadlines

On October 24, 2012, the U.S. Internal Revenue Service (IRS) issued Announcement 2012-42: Timelines for Due Diligence and Other Requirements Under FATCA (Announcement). The Announcement provides that final regulations (Final...more

U.S. Treasury/IRS Amend FATCA Rules And Extend Certain Deadlines

As we move toward the end of 2012, many non-U.S. financial institutions have been eager for information on how the Foreign Account Tax Compliance Act (FATCA) is going to be implemented. They are the entities which will have...more

A Collective Sigh of Relief: IRS Announces Revisions to Timelines for Due Diligence and Other Requirements under FATCA

Yesterday, in Announcement 2012-42, the Internal Revenue Service (IRS) announced its intention to modify proposed regulations issued in February 2012 by the IRS and Treasury Department that implement a set of statutory rules...more

ISDA Publishes 2012 FATCA Protocol

On August 15, 2012, the International Swaps and Derivatives Association (the "ISDA") opened the ISDA 2012 FATCA Protocol (the "FATCA Protocol") for adherence. The FATCA Protocol is intended to allow adherents to amend certain...more

Important Deadlines and Effective Dates Under Proposed FATCA Regulations

2013 • FFIs may begin to apply to enter into FFI agreements • To qualify for PFFI status by the time FATCA withholding first becomes effective on January 1, 2014, an FFI will be required to execute an FFI...more

FATCA Proposed Regulations Unveiled by Treasury

On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). In drafting the Proposed...more

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