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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

The Treasury Department and IRS Release Final FATCA Regulations

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

Significant Changes Made in Final FATCA Regulations

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

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

"Treasury and IRS Finalize Highly Anticipated FATCA Regulations"

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

Treasury Issues Final FATCA Regulations

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

U.S. Treasury/IRS Amend FATCA Rules And Extend Certain Deadlines

As we move toward the end of 2012, many non-U.S. financial institutions have been eager for information on how the Foreign Account Tax Compliance Act (FATCA) is going to be implemented. They are the entities which will have...more

United Kingdom and United States Conclude FATCA Intergovernmental Agreement

On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account...more

First Bilateral Agreement to Implement FATCA Signed by U.S. & United Kingdom

On September 14, 2012, the Treasury Department ("Treasury") announced that the United States has signed its first bilateral agreement with the United Kingdom regarding the implementation of the information reporting and...more

Foreign Financial Account “Due Diligence” Under FATCA

The recent agreement between the United States and Great Britain provides an example of inter-governmental cooperation on exchange of taxpayer financial account information. The agreement is mutual, meaning that the...more

U.S. Treasury Department Releases Model FATCA Intergovernmental Agreements

On July 26, 2012, the U.S. Department of Treasury released its first model intergovernmental agreement (IGA) implementing the information reporting and withholding tax provisions under the Foreign Account Tax Compliance Act...more

Treasury Releases FATCA Intergovernmental Model Agreements

On July 26, 2012, the U.S. Treasury Department (“Treasury”) released two model agreements that reflect the intergovernmental approach outlined in Treasury’s February joint statement with France, Germany, Italy, Spain, and the...more

U.S. Department of Treasury Publishes FATCA Intergovernmental Model Agreement

On July 26, 2012, the U.S. Department of Treasury ("Treasury") published the intergovernmental model agreement for government-to-government information sharing ("model agreement") to implement the information reporting and...more

FATCA G-5 Model Intergovernmental Information Sharing Agreements Released, with Substantial Benefits for Insurance Company FFIs...

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

Third FATCA Compliance Model Announced - Inter-Governmental Agreements

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

Final Proposed FATCA Regulations Issued

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

An Intergovernmental Approach to FATCA: US Treasury Issues Joint Statement From the United States, France, Germany, Italy, Spain...

On February 8, 2012, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations under the Foreign Account Tax Compliance Act (“FATCA”). FATCA establishes a new US...more

Next Phase of FATCA Guidance Arrives with Proposed Regulations and Announcement of Possible Intergovernmental Approach

On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more

FATCA Proposed Regulations Unveiled by Treasury

On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). In drafting the Proposed...more

Significant Developments for the Implementation of FATCA: The IRS and Treasury Department Release Proposed Regulations

On February 8, 2012, the Internal Revenue Service (IRS) and Treasury Department released long-awaited proposed regulations on a set of statutory rules commonly referred to as the Foreign Account Tax Compliance Act rules...more

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