News & Analysis as of

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

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

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

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

Cyprus and US sign FATCA IGA

On 2 December 2014, the US and Cyprus governments signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). There are two types of IGAs known as "Model 1" and "Model 2". The...more

Treasury Announces Relief for Countries with In-Substance FATCA IGAs

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

BVI's FATCA implementation continues

The implementation of the FATCA Intergovernmental agreements (IGAs) signed by the BVI with the US and the UK has taken another step forward by way of amendments to the Mutual Legal Assistance (Tax Matters) Act, 2003 (MLAT)...more

Hong Kong Signs FATCA IGA

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

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

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

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

FATCA Update: Brazil Signs IGA with U.S. and Treasury Releases More Guidance

On September 24, 2014, the government of Brazil announced it had signed an intergovernmental agreement with the United States as part of its adoption of the requirements of the Foreign Account Tax Compliance Act (FATCA). The...more

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

The Impact of FATCA on British Virgin Islands Funds

In March 2014, the British Virgin Islands Government announced that it had concluded negotiations with the US with respect to a Model 1B Intergovernmental Agreement with the United States (the IGA). The IGA (which was...more

BVI publishes draft FATCA Guidance Notes

In the latest moves towards implementation of the FATCA Intergovernmental agreements (IGAs) signed by the BVI with the US and the UK, the BVI Government has released draft Guidance Notes for public consultation. A copy can be...more

BVI Government signs Model 1B IGA in relation to FATCA

The BVI Government has signed a Model 1B (non-reciprocal) Intergovernmental Agreement (IGA) in relation to the US Foreign Account Tax Compliance Act (FATCA), it was announced on 30 June 2014....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

FATCA Update: Treasury and IRS Release Wave of Guidance as July 1 Approaches

With the July 1, 2014, implementation date of the Foreign Act Tax Compliance Act (FATCA) just two days away, the Treasury Department and the Internal Revenue Service have published long-awaited, and much anticipated, guidance...more

China and U.S. Conclude FATCA IGA In Substance

On June 26, 2014, China and the United States agreed on a Model 1 FATCA IGA. The Treasury did not say whether the agreement would be reciprocal. The IGA comes just in time for the July 1 start of 30 percent withholding on...more

Hong Kong’s Long-Awaited FATCA Announcement

With deadlines looming, Hong Kong’s government announced on May 9th a much-anticipated agreement with the United States regarding the U.S. Foreign Account Tax Compliance Act (FATCA). Without this intergovernmental agreement...more

FATCA is Coming

At the end of May 2014, a bill was introduced to the Australian Federal Parliament to give effect to the United States' Foreign Account Tax Compliance Act (FATCA) and the intergovernmental agreement which was executed by...more

IRS Extends FATCA Registration Deadline to May 5, 2014

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

BVI Financial Institutions now able to register with the IRS for a GINN

In a welcome announcement made on 2 April 2014, the US Internal Revenue Service (IRS) made provision for Financial Institutions in jurisdictions that have already reached an "agreement in substance" on the terms of a Model 1...more

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

Capital Thinking: Tax and Retirement

Tax Legislative Activity - Senate Finance Chairman Announces Drafts to be in Legislative Langauge - Senate Finance Committee Chairman Max Baucus (D-MT) announced last week that tax reform discussion drafts to be...more

"G20 Leaders Endorse Greater International Tax Transparency"

At last month’s summit in St. Petersburg, Russia, G20 leaders backed two ambitious proposals issued by the Organization for Economic Co-operation and Development (OECD), including the establishment of a global model for the...more

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