News & Analysis as of

Intergovernmental Agreements

Ukraine and USA signs treaty on FATCA

by Dentons on

On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of...more

Ukraine and USA signs treaty on FATCA (Ukrainian)

by Dentons on

On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of...more

Russian law on the priority of the RF Constitution over resolutions of intergovernmental human rights bodies

by White & Case LLP on

On 15 December 2015, Federal Constitutional Law No. 7-FKZ dated 14 December 2015 "On amendments to the Federal Constitutional Law 'On the Constitutional Court of the Russian Federation'" (the "Law") prepared pursuant to...more

Council confirms SRM for 1 January 2016

by Dentons on

The Council has confirmed that the single resolution mechanism (SRM) will enter into force on 1 January 2016 as planned. It says enough Member States have ratified the intergovernmental agreement (IGA) on the transfer and...more

Sen. Barrasso Introduces Carcieri Compromise Bill

by Dickinson Wright on

More than six years after the U.S. Supreme Court’s decision in Carcieri v. Salazar, Sen. John Barrasso (R-Wyoming), the chairman of the Senate Committee on Indian Affairs, has introduced the “Interior Improvement Act” to fix...more

Luxembourg rated as "Largely Compliant" by the OECD Global Forum

by DLA Piper on

On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg....more

Offshore Accounts Still Focus of IRS Enforcement

by Sanford Millar on

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client...more

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

by Blank Rome LLP on

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more

Financial Services Quarterly Report - Third Quarter 2015: Developments in the Luxembourg Financial Sector

by Dechert LLP on

The Luxembourg government has brought to Parliament a bill of law transposing UCITS V into Luxembourg’s UCI Law and AIFM Law. Further, the Luxembourg CSSF published a new version of its AIFMD Frequently Asked Questions, among...more

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

by Blank Rome LLP on

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010...more

Treasury, IRS Extend Certain FATCA Transitional Rules

by Morgan Lewis on

IRS Notice postpones several key deadlines and provides other relief. On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more

IRS Extends FATCA Transition Rules

On September 18, 2015, the Internal Revenue Service (IRS) issued Notice 2015-66, in which Treasury and the IRS announced that they intend to extend certain transition rules and modify certain other reporting rules under the...more

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

by Blank Rome LLP on

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

FATCA Update: Confidentiality of Information Transmitted to IRS; Announcement of “More Favorable” IGA Terms; and More IGAs

by Blank Rome LLP on

The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief...more

Due Date for FATCA Reporting of US Accounts Is Approaching

The deadline to report US accounts by offshore funds that are organized in Model 2 Intergovernmental Agreement (IGA) jurisdictions, such as Bermuda, as required by Foreign Account Tax Compliance Act (FATCA), is quickly...more

"FATCA Finally Takes Effect, Subject to Transition Rules"

After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S....more

FATCA Update: More Guidance, IGAs, Forms Announced by Treasury and IRS

by Blank Rome LLP on

1. The United States announced the signing of two more Intergovernmental Agreements (IGAs) to implement FATCA. The latest IGAs were signed by the Netherlands and Curacao, and are dated December 18 and 16, respectively. Both...more

Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

by Dechert LLP on

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For...more

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

by Blank Rome LLP on

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

Singapore Signs FATCA IGA

by BakerHostetler on

On December 9, 2014, Singapore’s Inland Revenue Authority announced that Singapore and the United States had on that day entered into a Model 1 FATCA IGA. ...more

Treasury Announces Relief for Countries with In-Substance FATCA IGAs

by BakerHostetler on

On December 1, 2014, the U.S. Treasury Department announced that countries that have reached FATCA inter-governmental agreements (IGAs) in substance but have not signed the agreements by the December 31 deadline will, under...more

Hong Kong Signs FATCA IGA

by BakerHostetler on

On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S....more

FATCA Alert

by Fowler White Burnett, P.A. on

In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign...more

Switzerland Announces Intention to Change from Model 2 IGA to Model 1

by BakerHostetler on

On October 8, 2014, Swiss officials announced that they intend to negotiate a reciprocal Model 1 FATCA IGA to replace the Model 2 IGA that they signed in 2013. The motivation for the change is unknown, but the automatic...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

by Blank Rome LLP on

First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more

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