FFI

A nuisance called FATCA – Does the UK/US IGA make it bearable?

by Peita Menon, Prabhu Narasimhan | White & Case LLP on 4/15/2013

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

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

by Adrienne Baker, Karl Paulson Egbert, Michael Hirschfeld | Dechert LLP on 3/27/2013

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

What You Need to Know About FATCA’s Impact on Non-U.S. Retirement Plans

by Kary Crassweller, Andrew C. Liazos, Todd Solomon | McDermott Will & Emery on 3/21/2013

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

FATCA And Voluntary Disclosure

by Michael Volkov on 3/7/2013

The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program...more

New Law Expands Scope of Iran Sanctions In New Ways

by Scott Maberry, Matthew Riemer | Sheppard Mullin Richter & Hampton LLP on 2/15/2013

As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more

Treasury Releases Final FATCA Regulations

by Richard J. Horne, Christina M. Iafe, Brian Silikovitz | Lowenstein Sandler LLP on 2/15/2013

On January 17, 2013, the U.S. Treasury Department released final regulations implementing sections 1471 through 1474 of the Internal Revenue Code (the “Code”), commonly known as the Foreign Account Tax Compliance Act or...more

Highlights of Recently Released FATCA Regulations

by Allen Littman, Michael Nydegger, Paul Schmidt | BakerHostetler on 2/13/2013

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

FATCA: Final Regulations Raise Questions for Trust Practitioners

by Sloane Jumper, Samantha Moore, John Nichols, Kurt Rademacher | Butler, Snow, O'Mara, Stevens and Cannada,... on 2/8/2013

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

FATCA Regulations Are Finalized

by Katten Muchin Rosenman LLP on 1/30/2013

On January 18, the Treasury Department issued final regulations under the Foreign Account Tax Compliance Act (FATCA). The final regulations incorporate the FATCA guidance that the Internal Revenue Service (IRS) has issued...more

U.S. Tax Authorities Issue Final FATCA Regulations

by Proskauer Rose LLP on 1/28/2013

On January 17, 2013, the U.S. Department of the Treasury (Treasury Department) and U.S. Internal Revenue Service (IRS) issued final Treasury Regulations (Final Regulations) under the tax provisions commonly referred to as the...more

Treasury and IRS FATCA Regulations

by Orrick - Structured Finance Group on 1/28/2013

On January 17, Treasury and the IRS issued comprehensive final regulations implementing the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA)....more

FATCA Regulations Finally Arrive: A First Look

by Mary Burke Baker, Andrés Gil, Adam Tejeda, Roger Wise | K&L Gates LLP on 1/23/2013

On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more

FATCA Model II Agreement Released

by Jonathan E. Gopman, Elysa R. Merlin, Barbara E. Ruiz-Gonzalez, Sherwin P. Simmons, II | Akerman Senterfitt on 12/6/2012

The U.S. Department of Treasury ("Treasury") recently released its second model agreement (the "Model II Agreement") for countries to implement the Foreign Account Tax Compliance Act ("FATCA"). FATCA requires foreign...more

Understanding FATCA

by Joan C. Arnold | Pepper Hamilton LLP on 12/3/2012

In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more

IRS Announces Revised FATCA Implementation Timelines

by Richard J. Horne, Christina M. Iafe, Brian Silikovitz | Lowenstein Sandler LLP on 11/29/2012

The Foreign Account Tax Compliance Act (“FATCA”) was enacted in 2010 as part of an effort to combat tax evasion by U.S. taxpayers holding investments in offshore accounts and through offshore intermediaries. FATCA creates a...more

IRS Announcement Extends FATCA Timelines

by Akerman Senterfitt on 11/5/2012

On October 24, 2012, the Internal Revenue Service ("IRS") and the Department of Treasury ("Treasury") issued an announcement that extends certain timelines for the implementation of Foreign Account Tax Compliance Act (FATCA)....more

Revisions to FATCA Implementation

by Morgan Lewis on 10/29/2012

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

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

by Patton Boggs LLP on 10/26/2012

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

by Ropes & Gray LLP on 10/26/2012

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

IRS Releases Draft Form to Certify Status Of Individuals for Withholding Under FATCA

by Akerman Senterfitt on 9/19/2012

On September 11, 2012, the Internal Revenue Service (“IRS”) released a new draft version of Form W-8 BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals). This Form is used...more

U.S. Treasury Department Releases Model FATCA Intergovernmental Agreements

by King & Spalding on 9/5/2012

On July 26, 2012, the U.S. Department of Treasury released its first model intergovernmental agreement (IGA) implementing the information reporting and withholding tax provisions under the Foreign Account Tax Compliance Act...more

FATCA’s Legal Issues

by White & Case LLP on 9/5/2012

To address concerns that US taxpayers were failing to report income generated in offshore accounts, the US Congress adopted Sections 1471 through 1474 of the Internal Revenue Code, commonly referred to as “FATCA,” in early...more

IRS Seeks Comment on New FATCA Forms; ISDA Announces FATCA-Driven Change to Master Agreement

by BakerHostetler on 8/17/2012

The IRS issued a request for comment on two new proposed FATCA-related forms on August 15, 2012. The first is Form 8956, Application for Foreign Account Tax Compliance Act (FATCA) Individual Identification Number. Each...more

IRS Issues Draft Withholding Forms Conforming To FATCA

by Akerman Senterfitt on 8/16/2012

The Foreign Account Tax Compliance Act ("FATCA"), passed as part of the Hiring Incentives to Restore Employment (HIRE) Act enacted in March 2010, added a requirement which generally provides that a foreign financial...more

FFIEC Releases Statement on Cloud Computing Risks and Considerations

by Richard Raysman | Holland & Knight LLP on 8/15/2012

The Federal Financial Institution Examination Council (FFIEC), an interagency body that advises a number of federal agencies on appropriate standards for the regulation of financial institutions, recently released a statement...more

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