U.S. Treasury Foreign Account Tax Compliance Act

News & Analysis as of

Bitcoin and the Like: Tax Considerations

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...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

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

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

Treasury Announces Relief for Countries with In-Substance FATCA IGAs

On December 1, 2014, the U.S. Treasury Department announced that countries that have reached FATCA inter-governmental agreements (IGAs) in substance but have not signed the agreements by the December 31 deadline will, under...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

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

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

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

Tax Evasion Gets Harder as FATCA Goes into Effect July 1

The Internal Revenue Service (IRS) will have more leverage over those seeking to minimize their tax bills by moving assets outside the U.S. when the Foreign Account Tax Compliance Act (FATCA) takes effect on July 1, 2014....more

The Steady March Toward FATCA Implementation: 77,000 Financial Institutions Registered and Nearly 70 IGAs Reached

On June 2, 2014, the U.S. Treasury and the Internal Revenue Service announced further developments as the July 1 implementation date of the Foreign Account Tax Compliance Act (FATCA) quickly approaches....more

FATCA and the Cyprus – US Connection

THE US DEPARTMENT OF TREASURY HAS ANNOUNCED that Cyprus and the US have reached agreement in substance as regards the Inter-Governmental Agreement for FATCA and Cyprus has consented to being included ...more

Treasury Extends FATCA Compliance Date, Announces Other Amendments Affecting Foreign Banks

The Internal Revenue Service (IRS) recently announced in Notice 2014-33 that 2014 and 2015 will be transitional years from an administrative and enforcement perspective regarding the implementation of the Foreign Account Tax...more

Hong Kong Agrees in Substance to FATCA IGA

On May 9, 2014, the U.S. Treasury announced that Hong Kong had agreed in substance on a Model 2 FATCA IGA. Under the IGA, Hong Kong financial institutions will report information on financial accounts held by U.S. persons...more

India Agrees “In Substance” to Model 1 FATCA IGA

The U.S. Treasury announced that on April 11, 2014, India agreed “in substance” to sign a Model 1 FATCA IGA with the US. The IGA would therefore require Indian financial institutions to report information on U.S. account...more

FATCA regulations updated but deadlines loom

The US Department of the Treasury and the Internal Revenue Service have released what they refer to as the “last substantial package of regulations” necessary to implement the Foreign Account Tax Compliance Act (FATCA). ...more

"Treasury and IRS Release FATCA Regulations"

New Regulations Address Some Concerns and Coordinate FATCA Rules with Other Reporting and Withholding Rules - On February 20, 2014, the Department of the Treasury and the IRS issued a comprehensive set of final and...more

Tax Law Blog: The Impact of FATCA

The U.S. government loses an estimated $150 billion in revenue each year from offshore tax shelters. The Foreign Account Tax Compliance Act (FATCA), which became law in March 2010, is designed to prevent tax evasion by U.S....more

U.S. Signs FATCA IGA With France

Bloomberg BNA reports that the Treasury Department announced on November 14, 2013, that the U.S. and France have signed a Model 1 FATCA IGA. In other words, the IGA will require banks in France to report tax information about...more

IRS releases long-awaited draft FFI Agreement and previews updates to FATCA regulations

The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA). ...more

"Treasury and IRS Move to Implement FATCA as 2014 Start Date Approaches"

On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010 as part of...more

Allocation of FATCA Withholding Risk in Financial Transactions Outside the United States

The U.S. Treasury Department has delayed implementation of FATCA once again. However, this delay may be the last, and a phased implementation of FATCA is scheduled to begin on July 1, 2014. FATCA introduces the potential for...more

IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting

On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43, which extended the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on...more

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