In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more
What if a U.S. Withholding Agent of a Foreign financial Institution (FFI) erroneously applies a 30% Internal Revenue Code (IRC) Chapter 4 FATCA Withholding to a payment to the FFI? What can be done to recover the funds? ...more
Little is written regarding FATCA and U.S. Financial Institutions (FI). That said, U.S. FIs have FATCA responsibilities. In the absence of permitted exceptions, FATCA requires U.S. FIs that make payments of most types of...more
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
On September 18, 2015, the Internal Revenue Service (IRS) issued Notice 2015-66, in which Treasury and the IRS announced that they intend to extend certain transition rules and modify certain other reporting rules under the...more
Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...more
On June 26, 2014, China and the United States agreed on a Model 1 FATCA IGA. The Treasury did not say whether the agreement would be reciprocal. The IGA comes just in time for the July 1 start of 30 percent withholding on...more
Notice 2013-43 (http://www.irs.gov/pub/irs-drop/n-13-43.pdf), released on July 12, 2013, announces the Internal Revenue Service's (the "IRS") and the Department of the Treasury's intent to amend final Treasury regulations...more
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more