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

No Place to Hide – FATCA Reporting Begins

Foreign asset reporting requirements are nothing new.  US taxpayers have long been required to report worldwide income, and the FBAR filing requirements have been around since the 1970s.  ...more

Portal for BVI FATCA Reporting Launched

The British Virgin Islands International Tax Authority (ITA) has launched its BVI Financial Account Reporting System (BVIFARS). The portal was opened yesterday and is ready to accept enrolment applications from BVI Reporting...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

FATCA: Upcoming Compliance Deadlines for Non-U.S. Financial Institutions

During the multi-year build-up to FATCA, the primary focus was on entity classification and registration, and less attention was paid to the compliance obligations of U.S. and non-U.S. entities affected by FATCA. Withholding...more

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more

Bitcoin and the Like: Tax Considerations

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more

Tax Policy Update

NUMBER OF THE WEEK: $23 Billion. The total revenue generated by the additional Medicare tax and the net investment income tax used to pay for the Affordable Care Act. The total exceeds the Joint Committee on Taxation’s 2010...more

Cayman issues User Guide to Automatic Exchange of Information Portal

As noted in an earlier update, the deadline for the registration of Cayman Islands Financial Institutions with the Cayman Islands Tax Information Authority was recently extended to 30 April 2015. In anticipation of the...more

BVI issues updated FATCA Guidance Notes

The International Tax Authority (ITA) of the British Virgin Islands has recently announced the issue of Version 2.0 of the Guidance Notes on the International Tax Compliance Requirements of the Intergovernmental Agreements...more

Due Date for FATCA Reporting of US Accounts Is Approaching

The deadline to report US accounts by offshore funds that are organized in Model 2 Intergovernmental Agreement (IGA) jurisdictions, such as Bermuda, as required by Foreign Account Tax Compliance Act (FATCA), is quickly...more

Corporate & Financial Weekly Digest - Volume X, Issue 11

In This Issue: - Delaware Proposal Banning Fee-Shifting and Permitting Exclusive Forum Provisions - SEC Charges Insiders for Failure to Update Schedule 13D Disclosures - CBOE Proposes Amendments to...more

Cayman Portal registration deadline extended

An update was released recently by the Cayman Islands Department of International Tax Cooperation in relation to the status of the Cayman Automated Exchange of Information Portal (Portal) and the requirement for Cayman...more

IRS Issues Further Revisions to Form 8938 Instructions

As part of the Foreign Account Tax Compliance Act (FATCA) passed by Congress in 2010, individual taxpayers are now required to report “specified foreign financial assets” on an information reporting form entitled Form 8938,...more

What Expats Need to Know Now about their Taxes, FATCA and the IRS

Are you an American abroad living in perpetual fear of the IRS? Do you wake up every morning wondering if today you’ll receive a formidable notice that the taxman cometh? You are not alone. ...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

EU Passes New Council Directive to Implement “EU-FATCA" - The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more

DOJ Warns Against Wrongful Use of Streamline Procedures

The U.S. Department of Justice is considering actions against taxpayers who wrongfully used the Streamlined Procedures to assert non-willful conduct. As quoted in Tax Notes Today...more

Dealing with Erroneous FATCA Inquiries

A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more

Investment Management Update - January 2015 [Video]

Investment Management Update - January 2015 This podcast is a recording of the January 2015 webinar that Pepper partner Gregory J. Nowak participated on for West LegalEdcenter. Mr. Nowak discussed a regulatory outlook...more

"FATCA Finally Takes Effect, Subject to Transition Rules"

After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S....more

FY 2016 Budget Tax Proposals Target Insurance Companies

On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S....more

2015 Estate and Tax Planning

Blank Rome’s annual estate planning newsletter discusses certain concepts and techniques that we hope may be of interest to our clients and friends....more

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

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