News & Analysis as of

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

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

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

Understanding FATCA

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 Announcement Extends FATCA Timelines

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

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

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

FATCA’s Legal Issues

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

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

Third FATCA Compliance Model Announced - Inter-Governmental Agreements

The U.S. Department of the Treasury (Treasury) issued joint statements with the governments of Japan and Switzerland on June 21, 2012 outlining a new framework for foreign financial institutions (FFIs) in those countries to...more

Proposed FATCA Regulations Feature InterGovernmental Approach

Sections 1471 through 1474, commonly referred to as the Foreign Account Tax Compliance Act (FATCA) were originally enacted as a part of the Hiring Incentives to Restore Employment Act on 3/18/10. FATCA requires foreign...more

Proposed Treasury Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

On February 8, 2012, the Internal Revenue Service (“IRS”) announced the release of proposed regulations (the “Proposed Regulations”) for the next phase of implementing reporting and withholding provisions of the HIRE Act...more

Final Proposed FATCA Regulations Issued

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on February 8, 2012 issued proposed regulations addressing the implementation of the Foreign Account Tax Compliance Act (“FATCA,” which was...more

Proposed Regulations Provide FATCA Compliance Guidance for Foreign Financial Institutions, Other Foreign Entities and U.S....

The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information...more

An Intergovernmental Approach to FATCA: US Treasury Issues Joint Statement From the United States, France, Germany, Italy, Spain...

On February 8, 2012, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations under the Foreign Account Tax Compliance Act (“FATCA”). FATCA establishes a new US...more

Next Phase of FATCA Guidance Arrives with Proposed Regulations and Announcement of Possible Intergovernmental Approach

On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more

"Highlights of Proposed Regulations Issued Under FATCA and Multijurisdiction Plan for Information Sharing"

On February 8, 2012, Treasury and the IRS issued comprehensive proposed regulations (Proposed Regulations) that would, when finalized, implement the Foreign Account Tax Compliance Act (FATCA), which was enacted in March 2010....more

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