El 12/30/22, el IRS emitió el Aviso 2023-11 con el propósito de proporcionar alivio de informes FATCA a las FFI Modelo 1 que no han podido obtener los TINs (“Tax ID Numbers”) de los EE. UU. para sus cuentas preexistentes que...more
On 12/30/22, the IRS issued Notice 2023-11 with the purpose of providing FATCA reporting relief to Model 1 FFIs who have been unable to obtain US TINs for their pre-existing accounts that are US reportable accounts. In turn,...more
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) addressing various aspects of the withholding...more
We have previously written about the Internal Revenue Service’s publication in late 2016 of an updated “FFI Agreement” to be entered into by foreign financial institutions that wish to remain compliant with the Foreign...more
FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
On July 26, 2012, the Treasury Department released two versions of a model intergovernmental agreement (model IGA) for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA). One...more
The U.S. Department of the Treasury (Treasury) issued joint statements with the governments of Japan and Switzerland on June 21, 2012 outlining a new framework for foreign financial institutions (FFIs) in those countries to...more
The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on February 8, 2012 issued proposed regulations addressing the implementation of the Foreign Account Tax Compliance Act (“FATCA,” which was...more
In This Presentation: FATCA: Foreign Account Tax Compliance Act - History - Nuts and Bolts - Highlights of Proposed Regulations - Intergovernmental Agreement - Next Steps - Q&A Please see full...more