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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

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

Treasury Delays FATCA Deadlines by Six Months

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

Treasury and IRS Extend FATCA Deadlines

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

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

FATCA Implementation Further Delayed Until July 1, 2014, FFIs Should Finalize Registrations by April 25, 2014

The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more

Treasury Delays Implementation of Certain Aspects of FATCA for Six Months

On July 12, 2013, the Internal Revenue Service (the “IRS”) released an advance copy of Notice 2013-43 (the “Notice”), which extends the timeline for the implementation of withholding, registration and due diligence...more

Timeline for Initial FATCA Implementation Extended

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more

Extension of FATCA Withholding Start Date and Grandfathering End Date

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

Revised Timeline for Implementing FATCA

Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more

Legal Alert: New Extended FATCA Implementation Dates

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

Treasury Revises FATCA Implementation Timeline

IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...more

IRS announces six-month delay in FATCA implementation

On Friday, the US Treasury Department and the Internal Revenue Service announced a six-month extension to the start of the FATCA withholding and account due diligence requirements. ...more

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more

FATCA: Final Regulations Raise Questions for Trust Practitioners

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

FATCA Model II Agreement Released

The U.S. Department of Treasury ("Treasury") recently released its second model agreement (the "Model II Agreement") for countries to implement the Foreign Account Tax Compliance Act ("FATCA"). FATCA requires foreign...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

A Collective Sigh of Relief: IRS Announces Revisions to Timelines for Due Diligence and Other Requirements under FATCA

Yesterday, in Announcement 2012-42, the Internal Revenue Service (IRS) announced its intention to modify proposed regulations issued in February 2012 by the IRS and Treasury Department that implement a set of statutory rules...more

IRS Releases Draft Form to Certify Status Of Individuals for Withholding Under FATCA

On September 11, 2012, the Internal Revenue Service (“IRS”) released a new draft version of Form W-8 BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals). This Form is used...more

U.S. Treasury Department Releases Model FATCA Intergovernmental Agreements

On July 26, 2012, the U.S. Department of Treasury released its first model intergovernmental agreement (IGA) implementing the information reporting and withholding tax provisions under the Foreign Account Tax Compliance Act...more

Treasury Releases FATCA Intergovernmental Model Agreements

On July 26, 2012, the U.S. Treasury Department (“Treasury”) released two model agreements that reflect the intergovernmental approach outlined in Treasury’s February joint statement with France, Germany, Italy, Spain, and the...more

U.S. Department of Treasury Publishes FATCA Intergovernmental Model Agreement

On July 26, 2012, the U.S. Department of Treasury ("Treasury") published the intergovernmental model agreement for government-to-government information sharing ("model agreement") to implement the information reporting and...more

FATCA G-5 Model Intergovernmental Information Sharing Agreements Released, with Substantial Benefits for Insurance Company FFIs...

On July 26, 2012, the Treasury Department released two versions of a model intergovernmental agreement (model IGA) for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA). One...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

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