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Foreign Account Tax Compliance Act Foreign Banks

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -

Will Your Offshore Bank or Cryptocurrency Exchange Turn You In to the IRS?

by Sanford Millar on

Well the results of the Foreign Account tax Compliance Act (“FATCA”) are coming in and the IRS will be stepping up audit of “holder” of unreported account. The exam targets will be U.S. taxpayers who own or control foreign...more

Treasury Hints That Regulatory Review May Target FATCA Regulations

by Fox Rothschild LLP on

In a report to the President recommending actions to eliminate or mitigate burdens imposed on taxpayers by eight specific tax regulations, the Treasury Department indicated that it is considering possible reforms of...more

FATCA Update: FFI Agreement Renewal Function Now Available

by Fox Rothschild LLP on

The Internal Revenue Service announced today that its FATCA FFI Registration system has been updated to allow foreign financial institutions to renew their FFI agreement with the IRS. Those financial institutions that are...more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

by Foodman CPAs & Advisors on

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

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

US FATCA: Deadline to Register Sponsored Entities Approaching

by Morgan Lewis on

Sponsoring entities should evaluate which of their sponsored entities should be registered via the IRS registration portal....more

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

by Blank Rome LLP on

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

by Latham & Watkins LLP on

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

by Akerman LLP on

On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more

Dealing with Erroneous FATCA Inquiries

A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

by Blank Rome LLP on

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

Non-U.S. Retirement Plans Must Comply with or Claim Exemption from FATCA by July 1

by McDermott Will & Emery on

In January 2013, the Internal Revenue Service (IRS) published final regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA is intended to make it more difficult for U.S. taxpayers to conceal assets held in...more

The Taxman Cometh for US Holders of Foreign Bank Accounts

by Ifrah PLLC on

U.S. citizens and residents with unreported assets abroad may be feeling a steady increase of pressure these days. The July 1, 2014 effective date of the Foreign Assets Tax Compliance Act (FATCA) is looming. The number of...more

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

by Morgan Lewis on

The IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more

Key issues for asset managers in 2014

by Allen & Overy LLP on

In this newsletter - U.S.: - Dodd-Frank Act – Designation of asset managers as systemically important financial institutions - Volcker Rule finalised with a more limited application to covered fund activities...more

IRS Extends FATCA Registration Deadline to May 5, 2014

by Holland & Knight LLP on

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

by Holland & Knight LLP on

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

FATCA: With Deadlines Looming, the Time to Act is Now

by Foley Hoag LLP on

On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more

U.S. Signs Four More FATCA IGA’s

by BakerHostetler on

On February 5, 2014, the Treasury Department announced that it had recently concluded FATCA IGA’s with Canada, Hungary, Italy, and Mauritius. All four agreements were reciprocal Model 1 agreements. In other words, FFI’s in...more

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

by Latham & Watkins LLP on

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

by K&L Gates LLP on

A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...more

Court Rules U.S. Banks Must Disclose Nonresident Bank Account Information

by Sanford Millar on

As a result of a court decision last week, issued by the District Court in the District of Columbia U.S banks will be required to report interest earned on accounts held be non-resident aliens if the interest earned is $10.00...more

Swiss Parliament Votes to Delay Enforcement of FATCA IGA By Six Months

by BakerHostetler on

Bloomberg BNA reports that Switzerland's parliament approved a six-month delay to enforce a bilateral Swiss-U.S. agreement on implementation of the U.S. Foreign Account Tax Compliance Act. The two chambers of the Swiss...more

IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting

by McDermott Will & Emery on

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

FATCA Implementation Further Delayed Until July 1, 2014, FFIs Should Finalize Registrations by April 25, 2014

The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more

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