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.... 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.
If you would like copies of an article that is not linked to a PDF file, or if you would like to receive copies of future articles, please contact Rebecca Sprunger at rsprunger@orrick.com. - 03-29-2013 (U.S.) Final...more
Interesting tax update courtesy of Bruce Thompson, a Senior Policy Advisor with DLA Piper. He continues to see momentum for comprehensive tax reform and wrote the following summary of what that might mean for fund managers...more
For taxpayer’s who had direct or indirect control over offshore financial accounts which aggregated $10,000 or more in calendar year 2012 a Report of Foreign Bank or Financial Account, known as an FBAR (Form TD 90-F. 22.1) is...more
This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more
Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more
Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a...more
The good news is that, under the recently released Foreign Account Tax Compliance Act (FATCA) regulations, most non-U.S. property and casualty (P&C) insurance and reinsurance companies will not be considered foreign financial...more
* Non-Enforcement Matters: - Legislation Reintroduced to Charge Investment Advisor User Fees - SEC Examination Program for Newly Registered Investment Advisers Reveals Common Areas of Concern - Recent...more
In This Issue: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives and Modify Certain Other Tax Rules; After Months of Anticipation, Final FATCA Regulations Released; Congress Considers...more
In This Issue: - General Legislative - Agriculture & Food - Budget, Appropriations and Sequestration - Cybersecurity - Defense - Education - Energy - Environment - Financial Services -...more
2013 is lining up to be a pivotal and successful year for both the Cayman Islands and the global hedge fund industry. Many of the developments which started in the last decade, ranging from worldwide regulatory and financial...more
On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more
The introduction by the US of the Foreign Account Tax Compliance Act 2010 (FATCA) set the proverbial cat amongst the pigeons in the international loan financing markets by requiring foreign and domestic borrowers, lenders and...more
Both jurisdictions also pledge to sign up to “UK FATCA” - The US Foreign Account Tax Compliance Act, commonly referred to as FATCA, became effective earlier this year, and foreign financial institutions (“FFIs”) in...more
In this presentation: - General Counsel’s Address - Keynote Address - General Session — It’s a Small World After All: How Non-U.S. Regulators Affect Your Business - General Session — Closer to...more
Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more
U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more
In This Issue: *Financial Industry Developments - CFTC No-Action Relief for Commodity Trader Advisor Registration - CFTC Regulations on Associated Persons of Swap Dealers and Major Swap Participants -...more
June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control...more
On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more
The Cayman Islands announced on March 15 that it intends to enter into a Model 1 Intergovernmental Agreement (IGA) with the Internal Revenue Service for Foreign Account Tax Compliance Act (FATCA) compliance purposes...more
In what is clearly the first of many to come intergovernmental agreements similar to the Foreign Account Tax Compliance Acct (FATCA) adopted by the U.S. in 2010, the governments of Switzerland and the United Kingdom entered...more
The Honourable Jim Flaherty, Minister of Finance, tabled Budget 2013 today. In his Budget Speech, the Minister lauded Canada’s economic strength and achievements over the last seven years, while acknowledging that there are...more
The Internal Revenue Service recently published final regulations under the Foreign Account Tax Compliance Act (FATCA), which are effective immediately. FATCA imposes significant reporting obligations on both non-U.S....more
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