Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -
News & Analysis as of

The World Wide Tax Web: FATCA Data Sharing Goes Online

The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to...more

Year in Review: Legislation and Guidance for Financial Institutions in 2014

2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review....more

When Do Non-U.S. Citizens Pay Income Tax And Report Foreign Financial Accounts?

In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes....more

FATCA Update: More Guidance, IGAs, Forms Announced by Treasury and IRS

1. The United States announced the signing of two more Intergovernmental Agreements (IGAs) to implement FATCA. The latest IGAs were signed by the Netherlands and Curacao, and are dated December 18 and 16, respectively. Both...more

The Death Of Hidden Offshore Accounts

The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing....more

New FATCA requirements apply to U.S. and non-U.S. insurers and insurance brokers on January 1, 2015

New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance...more

FATCA - A Consolidation of the BVI Mutual Legal Assistance (Tax Matters) Act, 2003

This guide presents a consolidation of the British Virgin Islands Mutual Legal Assistance (Tax Matters) Act, 2003. THE MUTUAL LEGAL ASSISTANCE (TAX MATTERS) ACT, 2003 - Based on the Mutual Legal Assistance (Tax...more

Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For...more

Spotlight On Federal Tax Developments In 2014

This article highlights a number of interesting federal tax developments that were brought to the table during the 2014 calendar year. Developments discussed in this article include the 18-month transitional period for the...more

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

Singapore Signs FATCA IGA

On December 9, 2014, Singapore’s Inland Revenue Authority announced that Singapore and the United States had on that day entered into a Model 1 FATCA IGA. ...more

Cyprus and US sign FATCA IGA

On 2 December 2014, the US and Cyprus governments signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). There are two types of IGAs known as "Model 1" and "Model 2". The...more

FATCA in Cayman: Deadline Approaches

The deadline for compliance with both US FATCA and UK FATCA fast approaches. Cayman entities which are classified as Financial Institutions are within the scope of FATCA. A typical Cayman fund will fall within the...more

FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more

FATCA Compliance Deadlines for December 2014

What Managers of U.S. and Non-U.S. Investment Funds Should Do Today - FATCA went into effect on July 1, 2014 and will be phased in through January 1, 2017. During that period, varying compliance deadlines apply to...more

Treasury Announces Relief for Countries with In-Substance FATCA IGAs

On December 1, 2014, the U.S. Treasury Department announced that countries that have reached FATCA inter-governmental agreements (IGAs) in substance but have not signed the agreements by the December 31 deadline will, under...more

BVI's FATCA implementation continues

The implementation of the FATCA Intergovernmental agreements (IGAs) signed by the BVI with the US and the UK has taken another step forward by way of amendments to the Mutual Legal Assistance (Tax Matters) Act, 2003 (MLAT)...more

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...more

Hong Kong Signs FATCA IGA

On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S....more

Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

The use of offshore SPVs in Shariah compliant transactions post-FATCA

In recent years and in the wake of the global financial crisis, international financial centers (IFCs) such as the British Virgin Islands (BVI) and the Cayman Islands (Cayman) have faced unprecedented political and regulatory...more

Informal Surrender Of Green Card Doesn’t Work

The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes....more

Automatic Exchange of Information: End to banking secrecy or flight of fancy? Common Reporting Standard

THE COMMON REPORTING STANDARD - On the 29 October 2014, a total of 51 jurisdictions signed a multilateral agreement to participate in the automatic exchange of information under the Common Reporting Standard ("CRS"). A...more

U.S. Will Disclose Swiss Bank Information

The Department of Justice (DOJ) recently made demand of 106 Swiss banks for information and cooperation under the terms of proposed Non-prosecution agreements (NPA). Non-prosecution agreements were offered to Swiss banks in...more

FATCA Alert

In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign...more

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