News & Analysis as of

Withholding Requirements Foreign Account Tax Compliance Act

Dorsey & Whitney LLP

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

Dorsey & Whitney LLP on

An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

Foodman CPAs & Advisors

Erroneous FACTA Withholding?

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

Foodman CPAs & Advisors

¿Qué sucede si una FFI pierde su GIIN?

Para estar registrado en FATCA y exento de retención por parte de los agentes de retención de los Estados Unidos, una institución financiera extranjera (“FFI”) debe de tener un número de identificación de intermediario global...more

Foodman CPAs & Advisors

What happens if an FFI loses its GIIN?

In order to be FATCA registered and exempt from withholding by U.S. withholding agents, a Foreign Financial Institution (FFI) must have a Global Intermediary Identification Number (GIIN). ...more

Hogan Lovells

FATCA tweaks kick "Passthru" withholding back to the future

Hogan Lovells on

Those of us who regularly review debt facilities have probably noticed that the prospective (earliest) application date for FATCA withholding on "gross proceeds” from sales or other dispositions and "foreign passthru...more

Eversheds Sutherland (US) LLP

The season of giving – proposed regulations ease FATCA reporting burdens

On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of the Internal Revenue Code...more

Dechert LLP

IRS Issues Proposed FATCA Regulations

Dechert LLP on

On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more

Foodman CPAs & Advisors

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

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

Proskauer - Tax Talks

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

Proskauer - Tax Talks on

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more

Morgan Lewis

Treasury, IRS Extend Certain FATCA Transitional Rules

Morgan Lewis on

IRS Notice postpones several key deadlines and provides other relief. On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more

Foley Hoag LLP

FATCA: IRS Extends Transitional Rules

Foley Hoag LLP on

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

Goulston & Storrs PC

IRS Will Extend Some FATCA Transition Rules

Goulston & Storrs PC on

In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on...more

Goodwin

IRS Notice 2014-33 – IRS Grants Relief for Good-Faith Efforts Under FATCA

Goodwin on

On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more

K&L Gates LLP

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

K&L Gates LLP on

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

Troutman Pepper

FATCA Withholding And Reporting Deferred For Six Months

Troutman Pepper on

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

K&L Gates LLP

The New World Wide Web: FATCA Inspires a Global Effort to Fight Tax Evasion

K&L Gates LLP on

The rapid evolution of the Foreign Account Tax Compliance Act (“FATCA”) from a U.S. driven effort to crack down on U.S. offshore tax evaders into an information reporting mechanism being considered for adoption throughout the...more

Orrick, Herrington & Sutcliffe LLP

Final Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more

Dechert LLP

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

Dechert LLP on

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

BakerHostetler

Highlights of Recently Released FATCA Regulations

BakerHostetler on

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

Dechert LLP

Significant Changes Made in Final FATCA Regulations

Dechert LLP on

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

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