Form W-8

News & Analysis as of

Tax Court Flexes Its Debt-Equity Muscle on “Unrelated” Parties

The Tax Court, in American Metallurgical Coal Co., TC Memo 2016-139, recently held that financing of a sale of partnership interests by a foreign seller to a U.S. buyer was not debt, but equity. The court found that the...more

Upcoming FATCA Deadlines

As noted in the Foley Adviser dated April 14, 2016, there are several upcoming FATCA-related deadlines, two of which are right around the corner: ..June 30, 2016: Foreign Financial Institution Due Diligence for...more

FATCA Update: IRS Issues Guidance Regarding Electronic Transmission of Forms W-8 and Updates Information Reporting Guides

The Internal Revenue Service has issued additional informal guidance regarding implementation of the Foreign Account Tax Compliance Act (FATCA). First, the IRS published a new “Frequently Asked Question” on its website...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

Highlights of Recently Released FATCA Regulations

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

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