Foreign Financial Institutions

News & Analysis as of

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

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

FATCA Update: Brazil Signs IGA with U.S. and Treasury Releases More Guidance

On September 24, 2014, the government of Brazil announced it had signed an intergovernmental agreement with the United States as part of its adoption of the requirements of the Foreign Account Tax Compliance Act (FATCA). The...more

FATCA Letters-What Should I Do Now?

As a result of the Foreign Account Tax Compliance Act, (FATCA), the latest estimates are that over 77,000 Foreign Financial Institutions (FFI’s) and over 80 foreign governments have entered into agreements to provide...more

17 Red Flags for Potential International-Sanctions Violations

Recent events in Ukraine and the Middle East have expanded sanctions placed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) against certain foreign financial institutions and individuals. This...more

IRS Issues FATCA Fraud Alert

As part of its continuing efforts to combat the serious problem of identity theft, the Internal Revenue Service warned today that fraudsters have expanded their widening schemes to obtain identity information to foreign...more

Saudi Capital Market Authority Publishes Draft Rules for Qualified Foreign Financial Institutions Investment in Listed Shares

Following last month’s announcement by the Saudi Arabian Capital Market Authority (the CMA) of its proposal to permit participation by qualified financial institutions directly on the Kingdom’s stock exchange (the Tadawul),...more

U.S. Tax Developments Affecting Financial Institutions and Products

Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more

Saudi Opens Market to Foreign Financial Institutions

In a long anticipated measure, the Saudi Council of Ministers (which is the highest authority in the Kingdom) issued a resolution on 21 July, 2014 authorizing foreign financial institutions to directly buy and sell stocks...more

After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014

More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA...more

FATCA Update: Treasury and IRS Release Wave of Guidance as July 1 Approaches

With the July 1, 2014, implementation date of the Foreign Act Tax Compliance Act (FATCA) just two days away, the Treasury Department and the Internal Revenue Service have published long-awaited, and much anticipated, guidance...more

China and U.S. Conclude FATCA IGA In Substance

On June 26, 2014, China and the United States agreed on a Model 1 FATCA IGA. The Treasury did not say whether the agreement would be reciprocal. The IGA comes just in time for the July 1 start of 30 percent withholding on...more

IRS Broadens Offshore Amnesty Program

Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more

FATCA is Coming

At the end of May 2014, a bill was introduced to the Australian Federal Parliament to give effect to the United States' Foreign Account Tax Compliance Act (FATCA) and the intergovernmental agreement which was executed by...more

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

Tax Evasion Gets Harder as FATCA Goes into Effect July 1

The Internal Revenue Service (IRS) will have more leverage over those seeking to minimize their tax bills by moving assets outside the U.S. when the Foreign Account Tax Compliance Act (FATCA) takes effect on July 1, 2014....more

The Steady March Toward FATCA Implementation: 77,000 Financial Institutions Registered and Nearly 70 IGAs Reached

On June 2, 2014, the U.S. Treasury and the Internal Revenue Service announced further developments as the July 1 implementation date of the Foreign Account Tax Compliance Act (FATCA) quickly approaches....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 Notice 2014-33 – IRS Grants Relief for Good-Faith Efforts Under FATCA

On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more

FATCA Transitional Relief and Extension of Time for the Implementation of New Account Procedures for Entity Investors

On May 2, the Internal Revenue Service issued a notice (Notice 2014-33) providing for a transition period for enforcing the withholding rules of the Foreign Account Tax Compliance Act (FATCA) and extending the period by which...more

Treasury Extends FATCA Compliance Date, Announces Other Amendments Affecting Foreign Banks

The Internal Revenue Service (IRS) recently announced in Notice 2014-33 that 2014 and 2015 will be transitional years from an administrative and enforcement perspective regarding the implementation of the Foreign Account Tax...more

IRS Declares 2014 and 2015 as a Transition Period for FATCA Administration and Enforcement and Provides an Additional Six Months...

Pursuant to Notice 2014-33 (the Notice), the IRS announced that it will treat calendar years 2014 and 2015 as a transition period for the administration and enforcement of the due diligence, reporting, and withholding...more

Deadlines Coming for Multinationals’ Retirement Plans and U.S. Taxpayers with Foreign Financial Interests

In 2010, the U.S. enacted a sweeping change in enforcement of its tax laws on foreign financial interests, the Foreign Account Tax Compliance Act (FATCA). The main thrust of the act is to penalize foreign financial...more

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