IRS, FATCA | JD Supra Law News

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

by Fuerst Ittleman David & Joseph, PL on 5/9/2013

Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more

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

Information Reporting for US Entities with Interests in Foreign Financial Assets Delayed

by Christopher Cawley, Nicola Lemay | Foley Hoag LLP on 4/4/2013

Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more

FATCA Compliance for Investment Fund Managers Part One

by Christopher Cawley, Nicola Lemay, Richard Schaul-Yoder | Foley Hoag LLP on 4/2/2013

U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

The 50% FBAR Penalty, Are you at Risk?

by Sanford Millar on 4/1/2013

June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control...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

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

FATCA And Voluntary Disclosure

by Michael Volkov on 3/7/2013

The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program...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

I.R.S. Issues FATCA Final Regulations

by Jonathan E. Gopman, Elysa R. Merlin, Barbara E. Ruiz-Gonzalez, Sherwin P. Simmons, II | Akerman Senterfitt on 1/31/2013

On January 17, 2013, the IRS released final regulations for the Foreign Account Tax Compliance Act ("FATCA") to be effective on January 28, 2013. Enacted by Congress in 2010, FATCA targets non-compliant U.S. taxpayers using...more

FATCA Regulations Are Finalized

by Katten Muchin Rosenman LLP on 1/30/2013

On January 18, the Treasury Department issued final regulations under the Foreign Account Tax Compliance Act (FATCA). The final regulations incorporate the FATCA guidance that the Internal Revenue Service (IRS) has issued...more

After Months of Anticipation, Final FATCA Regulations Released

by David de Ruig, David Goett, Thomas Humphreys, Remmelt Reigersman | Morrison & Foerster LLP on 1/30/2013

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act...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

Treasury and IRS FATCA Regulations

by Orrick - Structured Finance Group on 1/28/2013

On January 17, Treasury and the IRS issued comprehensive final regulations implementing the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA)....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

Final FATCA Rules Issued by U.S. Treasury Deparment: Future Impact Still Being Considered, But It Will Be Huge for International...

by Rosa Eckstein Schechter on 1/25/2013

This week, the Treasury Department released the Final Rules for FATCA -- the agency regulations that work to implement and enforce 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

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Internal Revenue Service › FATCA