News & Analysis as of

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

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

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

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

Initial FATCA Registration/Withholding Dates Draw Near

Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms. The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more

IRS Offers FATCA Relief, Extending Registration Deadline and Expanding Intergovernmental Agreement List

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

IRS Extends FATCA Registration Deadline to May 5, 2014

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

New FATCA Regulations Address Certain Concerns of the Insurance Industry

On February 20, Treasury and the IRS issued new final and temporary Foreign Account Tax Compliance Act (FATCA) regulations. In brief, the new FATCA regulations provide positive changes with respect to several issues raised...more

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

Tax Law Blog: The Impact of FATCA

The U.S. government loses an estimated $150 billion in revenue each year from offshore tax shelters. The Foreign Account Tax Compliance Act (FATCA), which became law in March 2010, is designed to prevent tax evasion by U.S....more

IRS releases long-awaited draft FFI Agreement and previews updates to FATCA regulations

The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA). ...more

FATCA Compliance Guidance Issued for Foreign Financial Institutions

The IRS has issued Notice 2013-69, which provides guidance to foreign financial institutions (FFIs) entering into a FATCA compliance agreement with IRS. The 50-page Notice also provides guidance to FFIs and their...more

Denis Kleinfeld: FATCA – Predictions of Implementation Failure Proving True

Denis Kleinfeld, Of Counsel to Fuerst Ittleman David & Joseph, is one of the nation”s most prolific writers in the field of International Tax Planning, and in recent years has focused his attention on the Foreign Account Tax...more

FATCA Update: IRS Introduces FATCA Registration Portal While Foreign Financial Institutions and U.S. Expatriates Push Back

On August 19, 2013 the Internal Revenue Service officially introduced its new registration portal (available here) to assist Foreign Financial Institutions (“FFI”) as they attempt to comply with the Foreign Account Tax...more

IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting

On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43, which extended the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on...more

74 Results
|
View per page
Page: of 3