BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
The Luxembourg government has brought to Parliament a bill of law transposing UCITS V into Luxembourg’s UCI Law and AIFM Law. Further, the Luxembourg CSSF published a new version of its AIFMD Frequently Asked Questions, among...more
Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more
On April 2, 2014, the U.S. Internal Revenue Service (IRS) issued Announcement 2014-17 (the Announcement), which provides certain FATCA relief. The Announcement extends from April 25, 2014 to May 5, 2014 the deadline by which...more
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
On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more
Notice 2013-43 (http://www.irs.gov/pub/irs-drop/n-13-43.pdf), released on July 12, 2013, announces the Internal Revenue Service's (the "IRS") and the Department of the Treasury's intent to amend final Treasury regulations...more
On July 12, Treasury and the IRS announced that they intend to amend final Treasury regulations implementing the U.S. Foreign Account Tax Compliance Act (FATCA) to provide for a six-month extension to the start of FATCA...more
On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more
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 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
2013 • FFIs may begin to apply to enter into FFI agreements • To qualify for PFFI status by the time FATCA withholding first becomes effective on January 1, 2014, an FFI will be required to execute an FFI...more
On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). In drafting the Proposed...more