Reporting Requirements Foreign Account Tax Compliance Act

News & Analysis as of

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

2015-16 Compliance Developments & Calendar for Private Fund Advisers

Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

Financial Services Quarterly Report - Third Quarter 2015: Developments in the Luxembourg Financial Sector

The Luxembourg government has brought to Parliament a bill of law transposing UCITS V into Luxembourg’s UCI Law and AIFM Law. Further, the Luxembourg CSSF published a new version of its AIFMD Frequently Asked Questions, among...more

FATCA: IRS Extends Transitional Rules

On September 18, 2015, the IRS announced its intention to amend the U.S. FATCA regulations to extend the effectiveness of certain transitional rules, including...more

FATCA Update: Institute of International Bankers Submits Comment Letter on FATCA Regulations

The Institute of International Bankers (IIB) has submitted a comment letter (available through Bloomberg BNA here; subscription required) to the Internal Revenue Service addressing various issues arising under the FATCA...more

FATCA: Making First Submissions and Maintaining Compliance

While the Foreign Account Tax Compliance Act (FATCA) became law in 2010, it has been slowly transitioning to implementation, with 2015 being the first year of required reportings. For anyone not familiar with the Act, FATCA...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

BVI FATCA Compliance Deadlines Extended

This week the British Virgin Islands (BVI) announced the extension of its FATCA registration and reporting deadlines, as follows...more

Top 10 Foreign Bank Account Reporting (FBAR) Mistakes (And How to Fix Them)

While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance. June 30th is the annual deadline for filing a Foreign...more

IRS Plans to Shift Risk of Withholding Agent Fraud to the Taxpayer for Foreign Withholding

Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also...more

FATCA: Upcoming Compliance Deadlines for Non-U.S. Financial Institutions

During the multi-year build-up to FATCA, the primary focus was on entity classification and registration, and less attention was paid to the compliance obligations of U.S. and non-U.S. entities affected by FATCA. Withholding...more

FATCA Update: More Guidance, IGAs, Forms Announced by Treasury and IRS

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

New FATCA requirements apply to U.S. and non-U.S. insurers and insurance brokers on January 1, 2015

New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance...more

FATCA Compliance Deadlines for December 2014

What Managers of U.S. and Non-U.S. Investment Funds Should Do Today - FATCA went into effect on July 1, 2014 and will be phased in through January 1, 2017. During that period, varying compliance deadlines apply to...more

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...more


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

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

2014-15 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more

FATCA Violation Underlies Latest US Tax and Securities Fraud Charges

Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation. On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...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

IRS Announces Changes to Its Offshore Voluntary Disclosure and Streamlined Procedures

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

IRS Broadens Offshore Amnesty Program

Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more

IRS Changes the Streamlined Filing Compliance Procedures and Offshore Voluntary Disclosure Program (OVDP) - Determining Your Most...

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014....more

IRS Announces Sweeping Changes To Its Offshore Voluntary Disclosure Programs: New Rules Effective July 1, 2014

On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...more

IRS Modifies Offshore Voluntary Disclosure Program and Expands Streamlined Procedures

On June 18, 2014, the Internal Revenue Service (IRS) announced major changes to its 2012 Offshore Voluntary Disclosure Program (OVDP) and streamlined procedures. The modifications provide new options to help both taxpayers...more

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