Bloomberg BNA reports that the Treasury Department announced on November 14, 2013, that the U.S. and France have signed a Model 1 FATCA IGA. In other words, the IGA will require banks in France to report tax information about...more
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).
The United Kingdom (U.K.) has published an agreed intergovernmental agreement (IGA) with the Cayman Islands. The IGA was signed on 5th November and is intended to improve international tax compliance by providing for domestic...more
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
At the most recent meeting of the Finance Ministers and Central Bank Governors on July 19 & 20, 2013 they said “We are committed to automatic exchange of information as the new, global standard and we fully support the OECD...more
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
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
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
On 12 July, just one working day before the secure portal to be used by FFIs to register their status was due to go live, the US Internal Revenue Service ("IRS") issued Notice 2013-43 ("the Notice") announcing the delay to...more
Notice 2013-43, 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 implementing the U.S. Foreign Account Tax...more
In This Issue:
IRS Leaves Potential REIT Conversions Hanging; IRS Proposes to Relax Wash Sale Rules for Floating NAV Money Market Fund Share Redemptions; IRS Confirms Mexican Land Trust Is Not Trust Under U.S. Tax Law;...more
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
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
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
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
On July 12, 2013, the IRS issued new guidance regarding FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers. In particular, the IRS (1) revised certain elements of the timeline for FATCA...more
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
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
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
In This Issue: Financial Industry Developments; Rating Agency Developments; RMBS and Other Securities Litigation; and, European Financial Industry Developments.
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
IRS notice postpones FATCA withholding by six months and revises other key deadlines.
On July 12, 2013, the U.S. Internal Revenue Service (IRS) issued Notice 2013-43 (Notice) which extends certain key deadlines for implementing FATCA, and provides guidance regarding the effect of these deadlines on FATCA...more
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
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more