Intergovernmental Agreements, FATCA

A nuisance called FATCA – Does the UK/US IGA make it bearable?

by Peita Menon, Prabhu Narasimhan | White & Case LLP on 4/15/2013

The introduction by the US of the Foreign Account Tax Compliance Act 2010 (FATCA) set the proverbial cat amongst the pigeons in the international loan financing markets by requiring foreign and domestic borrowers, lenders and...more

BVI and Cayman to enter into FATCA Model 1 agreements with United States

by Jonathan Culshaw, Ross Munro, Peter Tarn | Harney Westwood & Riegels on 4/12/2013

Both jurisdictions also pledge to sign up to “UK FATCA” - The US Foreign Account Tax Compliance Act, commonly referred to as FATCA, became effective earlier this year, and foreign financial institutions (“FFIs”) in...more

Final Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

by Orrick, Herrington & Sutcliffe LLP on 3/29/2013

On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more

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

by Adrienne Baker, Karl Paulson Egbert, Michael Hirschfeld | Dechert LLP on 3/27/2013

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

Cayman Islands to Enter into a Model 1 IGA

by Katten Muchin Rosenman LLP on 3/26/2013

The Cayman Islands announced on March 15 that it intends to enter into a Model 1 Intergovernmental Agreement (IGA) with the Internal Revenue Service for Foreign Account Tax Compliance Act (FATCA) compliance purposes...more

Son of FATCA – Swiss/U.K. Agree on Information Exchange

by Sanford Millar on 3/25/2013

In what is clearly the first of many to come intergovernmental agreements similar to the Foreign Account Tax Compliance Acct (FATCA) adopted by the U.S. in 2010, the governments of Switzerland and the United Kingdom entered...more

What You Need to Know About FATCA’s Impact on Non-U.S. Retirement Plans

by Kary Crassweller, Andrew C. Liazos, Todd Solomon | McDermott Will & Emery on 3/21/2013

The Internal Revenue Service recently published final regulations under the Foreign Account Tax Compliance Act (FATCA), which are effective immediately. FATCA imposes significant reporting obligations on both non-U.S....more

The Treasury Department and IRS Release Final FATCA Regulations

by Ropes & Gray LLP on 2/22/2013

On January 17, 2013, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released long-awaited final regulations on the set of statutory rules commonly referred to as FATCA. As more fully described in...more

Treasury Releases Final FATCA Regulations

by Richard J. Horne, Christina M. Iafe, Brian Silikovitz | Lowenstein Sandler LLP on 2/15/2013

On January 17, 2013, the U.S. Treasury Department released final regulations implementing sections 1471 through 1474 of the Internal Revenue Code (the “Code”), commonly known as the Foreign Account Tax Compliance Act or...more

Highlights of Recently Released FATCA Regulations

by Allen Littman, Michael Nydegger, Paul Schmidt | BakerHostetler on 2/13/2013

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

Significant Changes Made in Final FATCA Regulations

by Adrienne Baker, Andrew Bloom, Michael Hirschfeld | Dechert LLP on 2/11/2013

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

FATCA: Final Regulations Raise Questions for Trust Practitioners

by Sloane Jumper, Samantha Moore, John Nichols, Kurt Rademacher | Butler, Snow, O'Mara, Stevens and Cannada,... on 2/8/2013

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

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: FATCA Update – No Duplicate Reporting for Investment...

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 2/8/2013

Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more

U.S. Tax Authorities Issue Final FATCA Regulations

by Proskauer Rose LLP on 1/28/2013

On January 17, 2013, the U.S. Department of the Treasury (Treasury Department) and U.S. Internal Revenue Service (IRS) issued final Treasury Regulations (Final Regulations) under the tax provisions commonly referred to as the...more

Tax Talk -- Volume 5, No. 4 -- January 2013

by David de Ruig, Stephen Feldman, David Goett, Thomas Humphreys, Meimay Law, Anna T. Pinedo, Remmelt Reigersman | Morrison & Foerster LLP on 1/28/2013

In This Issue: Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from...more

"Treasury and IRS Finalize Highly Anticipated FATCA Regulations"

by Jared Binstock, Roseann Cutrone, Pamela Lawrence Endreny, Edward Gonzalez, Yvonne Lee | Skadden, Arps, Slate, Meagher & Flom LLP on 1/25/2013

On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more

Treasury Issues Final FATCA Regulations

by Jeremy Naylor, Ray Simon | White & Case LLP on 1/24/2013

Introduction - On January 17, 2013, the Department of the Treasury (“the Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Regulations”) under Sections 1471 through 1474 of the...more

FATCA Regulations Finally Arrive: A First Look

by Mary Burke Baker, Andrés Gil, Adam Tejeda, Roger Wise | K&L Gates LLP on 1/23/2013

On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more

Understanding FATCA

by Joan C. Arnold | Pepper Hamilton LLP on 12/3/2012

In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more

U.S. Treasury/IRS Amend FATCA Rules And Extend Certain Deadlines

by Patton Boggs LLP on 10/26/2012

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

United Kingdom and United States Conclude FATCA Intergovernmental Agreement

by Proskauer Rose LLP on 9/25/2012

On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account...more

First Bilateral Agreement to Implement FATCA Signed by U.S. & United Kingdom

by Akerman Senterfitt on 9/19/2012

On September 14, 2012, the Treasury Department ("Treasury") announced that the United States has signed its first bilateral agreement with the United Kingdom regarding the implementation of the information reporting and...more

Foreign Financial Account “Due Diligence” Under FATCA

by Sanford Millar on 9/18/2012

The recent agreement between the United States and Great Britain provides an example of inter-governmental cooperation on exchange of taxpayer financial account information. The agreement is mutual, meaning that the...more

U.S. Treasury Department Releases Model FATCA Intergovernmental Agreements

by King & Spalding on 9/5/2012

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

ISDA Publishes 2012 FATCA Protocol

by Proskauer Rose LLP on 8/28/2012

On August 15, 2012, the International Swaps and Derivatives Association (the "ISDA") opened the ISDA 2012 FATCA Protocol (the "FATCA Protocol") for adherence. The FATCA Protocol is intended to allow adherents to amend certain...more

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Intergovernmental Agreements › FATCA