On January 17, 2013, the U.S. Treasury Department released final regulations implementing sections 1471 through 1474 of the Internal Revenue Code (the “Code”), commonly known as the Foreign Account Tax Compliance Act or...more
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
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
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, 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
On February 8, 2012, the IRS and US Treasury released 389 pages of proposed regulations under the Foreign Account Tax Compliance Act (FATCA), which was enacted for the purpose of combating offshore tax evasion. To achieve...more
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