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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the FATCA Intergovernmental agreements (IGAs) signed by the BVI with the US and the UK, the BVI Government has released draft Guidance Notes for public consultation.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

Denis Kleinfeld: FATCA – Predictions of Implementation Failure Proving True

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

Cayman Islands Government Announces FATCA Intergovernmental Agreement

The Cayman Islands government announced on August 13, 2013 that it has concluded negotiations with the US government on a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act...more

The New World Wide Web: FATCA Inspires a Global Effort to Fight Tax Evasion

The rapid evolution of the Foreign Account Tax Compliance Act (“FATCA”) from a U.S. driven effort to crack down on U.S. offshore tax evaders into an information reporting mechanism being considered for adoption throughout the...more

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

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

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”)

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

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

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

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

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

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