Foreign Account Tax Compliance Act Foreign Banks

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

Non-U.S. Retirement Plans Must Comply with or Claim Exemption from FATCA by July 1

In January 2013, the Internal Revenue Service (IRS) published final regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA is intended to make it more difficult for U.S. taxpayers to conceal assets held in...more

International Tax Compliance Update: IRS Hints at Coming Changes for Certain OVDP Filers

Remarks on Monday by John Koskinen, the Commissioner of Internal Revenue, indicate that the IRS is close to conceding to outside pressure to more clearly distinguish between Offshore Voluntary Disclosure Program (OVDP) filers...more

The Taxman Cometh for US Holders of Foreign Bank Accounts

U.S. citizens and residents with unreported assets abroad may be feeling a steady increase of pressure these days. The July 1, 2014 effective date of the Foreign Assets Tax Compliance Act (FATCA) is looming. The number of...more

FATCA Update: As Additional Countries Agree to Share International Tax Information, Hiding Assets Abroad becomes Increasingly...

In recent years the United States has increasingly amplified the pressure on United States persons to disclose assets they hold and income they earn abroad, especially relating to offshore financial accounts. Two prominent...more

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

The IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more

Key issues for asset managers in 2014

In this newsletter - U.S.: - Dodd-Frank Act – Designation of asset managers as systemically important financial institutions - Volcker Rule finalised with a more limited application to covered fund activities...more

IRS Extends FATCA Registration Deadline to May 5, 2014

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...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

U.S. Signs Four More FATCA IGA’s

On February 5, 2014, the Treasury Department announced that it had recently concluded FATCA IGA’s with Canada, Hungary, Italy, and Mauritius. All four agreements were reciprocal Model 1 agreements. In other words, FFI’s in...more

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...more

Court Rules U.S. Banks Must Disclose Nonresident Bank Account Information

As a result of a court decision last week, issued by the District Court in the District of Columbia U.S banks will be required to report interest earned on accounts held be non-resident aliens if the interest earned is $10.00...more

Swiss Parliament Votes to Delay Enforcement of FATCA IGA By Six Months

Bloomberg BNA reports that Switzerland's parliament approved a six-month delay to enforce a bilateral Swiss-U.S. agreement on implementation of the U.S. Foreign Account Tax Compliance Act. The two chambers of the Swiss...more

U.S. Department of Justice & Swiss Federal Department of Finance Enter into Historic Agreement Regarding Tax Evasion...

Continuing its mission to eradicate offshore tax evasion, on August 29, 2013, the United States Department of Justice Tax Division (the “DOJ”) and the Swiss Federal Department of Finance issued a Joint Statement regarding the...more

IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting

On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43, which extended the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on...more

FATCA Compliance Update: U.S. Treasury Announces Six Month Delay In Implementing FATCA

On July 12, 2013, the U.S. Treasury announced that due to overwhelming concern from countries around the world, the implementation of FATCA (the Foreign Account Tax Compliance Act) would be deferred from January 1, 2014 to...more

FATCA Implementation Further Delayed Until July 1, 2014, FFIs Should Finalize Registrations by April 25, 2014

The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more

Timeline for Initial FATCA Implementation Extended

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more

Orrick's Financial Industry Week In Review - July 15, 2013

In This Issue: Financial Industry Developments; Rating Agency Developments; RMBS and Other Securities Litigation; and, European Financial Industry Developments. ...more

Treasury Revises FATCA Implementation Timeline

IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...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 announces six-month delay in FATCA implementation

On Friday, the US Treasury Department and the Internal Revenue Service announced a six-month extension to the start of the FATCA withholding and account due diligence requirements. ...more

FATCA Withholding And Reporting Deferred For Six Months

In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more

Highlights of Recently Released FATCA Regulations

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

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