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Foreign Financial Institutions Internal Revenue Service

FATCA Update: IRS Releases Updated FATCA Online Registration User Guide

by Fox Rothschild LLP on

The Internal Revenue Service has released an updated version of its “FATCA Online Registration User Guide.” The updates primarily address the newly-released FFI agreement renewal function, which is now available on the IRS...more

FATCA Update: FFI Agreement Renewal Function Now Available

by Fox Rothschild LLP on

The Internal Revenue Service announced today that its FATCA FFI Registration system has been updated to allow foreign financial institutions to renew their FFI agreement with the IRS. Those financial institutions that are...more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

by Foodman CPAs & Advisors on

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

FATCA Update: IRS Reminds FFIs To Renew Their FFI Agreements By July 31, 2017

by Fox Rothschild LLP on

Following its publication on December 30, 2016, of an updated FFI agreement, the Internal Revenue Service has published a reminder to financial institutions about renewing their FFI agreement. All financial institutions that...more

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

by Proskauer - Tax Talks on

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more

FATCA: Final Deadline to Obtain a GIIN for Sponsored Investment Funds

Key Points - - Transitional relief for non-U.S. investment funds that have been previously permitted to provide only a sponsor’s GIIN to avoid incurring FATCA withholding ends on December 31, 2016. - U.S....more

If you are an “Expat”, or thinking about “Expatriating”, think about this!

by Foodman CPAs & Advisors on

Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more

New Regulations on F Reorganizations

by Alston & Bird on

In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

by Blank Rome LLP on

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010...more

It's Here; The Automatic Exchange of Information Under FATCA Began September 30th

by Sanford Millar on

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the...more

IRS Will Extend Some FATCA Transition Rules

by Goulston & Storrs PC on

In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on...more

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement

by BakerHostetler on

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

IRS Plans to Shift Risk of Withholding Agent Fraud to the Taxpayer for Foreign Withholding

by Charles (Chuck) Rubin on

Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

by Latham & Watkins LLP on

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

What Expats Need to Know Now about their Taxes, FATCA and the IRS

by Ifrah PLLC on

Are you an American abroad living in perpetual fear of the IRS? Do you wake up every morning wondering if today you’ll receive a formidable notice that the taxman cometh? You are not alone. ...more

The World Wide Tax Web: FATCA Data Sharing Goes Online

by Ifrah PLLC on

The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to...more

FATCA Update: More Guidance, IGAs, Forms Announced by Treasury and IRS

by Blank Rome LLP on

1. The United States announced the signing of two more Intergovernmental Agreements (IGAs) to implement FATCA. The latest IGAs were signed by the Netherlands and Curacao, and are dated December 18 and 16, respectively. Both...more

The Death Of Hidden Offshore Accounts

by Sanford Millar on

The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing....more

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

by Blank Rome LLP on

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

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

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

by Blank Rome LLP on

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

by BakerHostetler on

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

by Fowler White Burnett, P.A. on

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

by Blank Rome LLP on

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

IRS Issues FATCA Fraud Alert

by Blank Rome LLP on

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

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