David Weisner. Carolina Caballero. Today s Speakers. U.S. Tax Counsel for Asia Pacific. Citi

Size: px
Start display at page:

Download "David Weisner. Carolina Caballero. Today s Speakers. U.S. Tax Counsel for Asia Pacific. Citi"

Transcription

1

2 1

3 2

4 Understanding FATCA David Weisner, U.S. Tax Counsel for Asia Pacific, Citi Carolina Caballero, Product Risk and Regulatory Strategy Manager, Clearing and FI Payments, Citi Treasury and Trade Solutions 3 Citi Transaction Banking Academy for Financial Institutions Professionals 18 March 2014

5 Today s Speakers David Weisner U.S. Tax Counsel for Asia Pacific Citi Carolina Caballero Product Risk and Regulatory Strategy, Clearing & FI Payments Citi Treasury and Trade Solutions 4

6 5 This presentation does not constitute tax advice. It is for information purposes only.

7 Table of Contents 1. Background on FATCA 2. Due Diligence Requirements 3. Impact on Transactional Documentation 4. Intergovernmental Agreements 5. Timelines /What to Do Next 6. Questions and Answers 6

8 1. Background on FATCA 7

9 What is FATCA? Foreign Account Tax Compliance Act or FATCA was signed into law on March 18, 2010 as a revenue raiser for the Hiring Incentives to Restore Employment Act or HIRE Revenue estimate $8.7 billion over 10 years Response to hearings conducted by the Senate Permanent Subcommittee on Investigations and findings of substantial offshore tax evasion Various effective dates. FATCA withholding on U.S. source income begins on July1, 2014 Objective is to combat offshore tax evasion by U.S. persons who invest: Directly through financial accounts maintained offshore; and/or Indirectly through ownership of foreign entities FATCA works by requiring foreign financial institutions ( FFIs ) and non-financial foreign entities ( NFFEs ) to provide this information FATCA s lever is a NEW 30% withholding tax levied on withholdable payments to non-participating FFIs and NFFEs 8

10 Withholding as an Enforcement Tool 30 Percent FATCA Withholding Imposed on withholdable payments, including: U.S. source income from securities Interest on bank deposit accounts maintained in the United States or in a foreign branch of a U.S. bank Gross proceeds from the sale/redemption of U.S. securities When made to FFIs or NFFEs unless: the FFI enters into an agreement with the IRS (a participating FFI) or can be classified as a deemed-compliant FFI given that it presents a low risk of being used for tax evasion the NFFE discloses the identity of its U.S. owners or certifies to non-us ownership to the withholding agent or can be classified as an exempt NFFE given that it presents a low risk of being used for tax evasion 9

11 Example: Impact if a Bank Does Not Comply with FATCA Interest Income $100 Malaysian Bank (FFI) Gross Sales Proceeds $2000 US Withholding tax $30 US Treasury Securities US Withholding tax $600 Malaysian Bank invests in US Treasury securities that generate US source interest income and eventually gross proceeds from sale If Bank does not comply with FATCA, a new 30% US withholding tax will apply to payments of interest income and gross sale proceeds 10

12 Example FATCA Impact on Interest Rate Swap Fixed Rate Floating Rate CCiti U.S. Cash Collateral Interest on collateral Cash Collateral or U.S. Treasuries Interest on collateral FFFI Fixed rate payment no FATCA withholding; non-u.s. source. Floating rate payment no FATCA withholding; made to a U.S. financial institution. Interest on collateral paid by FFI no FATCA withholding; made to a U.S. financial institution. Interest on collateral paid by Citi U.S. FATCA withholding on the gross amount (no netting) unless FFI is FATCA compliant; U.S. source. 11

13 Besides Withholding - Impact of Non Compliance By a FFIs Competitiveness Some PFFIs might close accounts held by non-participating FFIs and recalcitrant customers. This will adversely impact the FFI s business. Impact on Product offerings Some products of FFIs will have to be limited to only participating FFIs. Impact on financing for international business which would like to secure financing from FFIs in for example Malaysia, if any of these financing involve US source payment (i.e. borrower being US corporates, local branches of US corporates), those borrowers will shy away from non-participating FFIs in Malaysia as the borrower will have to withhold 30% tax on repayment of such financing facilities. Channelling business away from FFIs in light of the potential 30% tax withholding, some international financial institutions may begin to channel business away from a FFI particularly business involving US source payments. 12

14 What is an FFI? Any non-u.s. entity that falls into one of the following categories: Accepts deposits in the ordinary course of a banking or similar business (e.g., a bank,). Holds, as a substantial part of its business, financial assets for the benefit of others (e.g., a custodian, broker-dealers, trust companies, clearing organizations). Is an investment entity (e.g., hedge funds, private equity funds, special purpose investment vehicles (SPVs), investment managers). An insurance company that issues annuities or cash value insurance policies. 13

15 What is Expected of an FFI? To avoid 30 percent withholding under FATCA, a FFI must enter into agreement with IRS and meet the following obligations or be classified as deemed-compliant as it presents a low risk of tax evasion: Comply with verification and due diligence procedures to be prescribed by Treasury Obtain information necessary to determine if each account is a U.S. account File annual reports with the IRS on U.S. accounts Withhold and pay the IRS 30 percent of withholdable payments made to: Recalcitrant account holders, Non-compliant FFIs, and FFIs electing to be withheld upon Comply with IRS requests for additional information on U.S. accounts Obtain a waiver of foreign laws that would prevent disclosure (e.g., privacy or bank secrecy laws) or close any account failing to provide a required waiver. The IRS can terminate the FFI agreement for any performance failures. All FFIs in expanded affiliated group need to be compliant in order for any FFI in that expanded affiliated group to be compliant. 14

16 Non-Financial Foreign Entity ( NFFE ) Defined An NFFE that has one or more substantial U.S. owners (other than a specified U.S. persons owners) is considered a U.S. owned NFFE Substantial ownership generally means more than 10 percent of: Vote or value of a corporation s stock Profit or capital interest in a partnership Beneficial interest in a trust if any grantor is a non-exempt US person Example: A closely-held manufacturing company Certain types of NFFEs are not required to disclose their U.S. owners. These include: A corporation the stock of which is regularly traded on an established securities market and any of its affiliates Active entities (less than 50% of income or assets is passive) 15

17 IRS Portal Portal is open now. FFIs who register are considered Participating FFIs Once an FFI has registered, the IRS will approve its registration and issue a GIIN (Global Intermediary Identification Number) to each Participating FFI and registered deemed compliant FFI. Portal will be primary means for FFIs to interact with the IRS to complete and maintain their FATCA registrations, agreements and certifications. Portal will be used for registration, electronic communication between the IRS and FFIs and other registrants and other FATCA communications. A GIIN will be assigned and will be used as the ID number for satisfying the FFI s reporting obligations and identifying its status to a withholding agent. The IRS will electronically post the first IRS list of Participating FFIs and registered deemed compliant FFIs (including Model 1 FFIs) on June 2, 2014, and will update the list on a monthly basis. The last date by which an FFI can register with the IRS to ensure inclusion on June 2, 2014 list is April 25,

18 2. FATCA Due Diligence Requirements 17

19 How to Classify Accounts Under FATCA FIs need to determine whether to treat: An individual account holder as a U.S. person or a foreign person An entity account holder as: a U.S. person A foreign financial institution (FFI) An exempt foreign organization (e.g., a foreign government) or A non-financial foreign entity (NFFE) An FFI as: A participating FFI A deemed-compliant FFI or Non-participating FFI An NFFE as: An excepted NFFE or A passive NFFE (having a substantial US owner) Presents a new and completely different way to categorize client accounts and service providers A payor generally cannot treat an FFI as FATCA compliant unless it has received valid documentation prior to the time a U.S. source income payment is made 18

20 Definition of a US Person U.S. individual U.S. citizen (by birth or naturalization). A dual citizen where one country of citizenship is the U.S. Non-U.S. citizen that is a U.S. permanent resident (i.e. green card holder). Non-U.S. citizen with substantial presence in U.S. (greater than 183 days). 31 days during current calendar year, AND 183 days during 3-year period including current year and 2 prior years All of the days present during current calendar year. 1/3 days present during 1 year before current year. 1/6 days present during 2 years before current year. U.S. Partnership U.S. Corporation U.S. LLC U.S. Trust or Estate U.S. Government, State, District of Columbia (or any agency or instrumentality thereof) A foreign person is any person that is not a U.S. person 19.

21 FFI Agreements Requirements FFI Agreements are effective on or after 1 July 2014 PFFI must adopt written policies and procedures regarding due diligence processes PFFI must conduct periodic internal reviews of its compliance with these policies and procedures and its FATCA obligations Observation: US tax authorities will not require mandatory external audits of PFFIs Within 1 Year of FFI Agreement Complete review of all high-value accounts, including the relationship manager query Perform the requisite review and obtain documentation for all prima facie FFIs Form W-8IMY on file indicates entity is a QI or NQI Complete a responsible officer certification stating Review of all high-value individual accounts is complete There were no formal or informal procedures in place from 6 August 2011, on to assist account holders in avoidance of Chapter 4 provisions Within 2 Years of FFI Agreement Complete review of individual accounts not previously identified as US accounts and obtain necessary documentation Complete review of pre-existing entity accounts not previously identified as a prima facie FFIs Complete a responsible officer certification stating PFFI has completed the account identification procedures and documentation requirements for all financial accounts that are pre-existing obligations, or if not, that it treats the accounts in accordance with the requirements as outlined in the FFI Agreement 20

22 Summary of Due Diligence for Pre-existing Accounts at a PFFI Account Type Exempted Completed Within Two years of FFI Agreement Completed Within One year of FFI Agreement Individuals US$50,000 or Less US$50,000 1,000,000 High Value >US$1,000,000 Exempted Electronic Search for US Indicia Electronic Search for US Indicia Manual Search as Required Relationship Manager Query Entities US$250,000 or Less Exempted > US$250,000 Review AML / KYC documentation Document FATCA Status Prima Facie FFIs (must be completed within 6 months of FFI Agreement ) Review AML / KYC documentation Document FATCA Status 21

23 New Account Due Diligence The presumptions may be rebutted obtaining the documentation sufficient to determine the FATCA status of the payee or account holder. For New Accounts: - FFIs must obtain sufficient documentation to identify and classify the payee/account holder - Must use Form W-9 to document U.S. persons - For offshore obligations, FFIs can rely on documentary evidence or written statements to establish foreign status - If there are any U.S. indicia, additional documentation must be obtained to substantiate foreign status - PFFIs must obtain a waiver from U.S. persons in any jurisdiction where local law would prevent disclosure or reporting to IRS 22

24 Client Management Issues Prospecting Certain products and services may no longer be available. On-Boarding New clients must provide personal information beyond current requirements Account Management Changes to client data may trigger additional requests; clients may be wary of certain products, services or transactions. Reporting Clients must waive privacy rights and grant permission of information to reported Off-boarding- Recalcitrant accounts may require closure 23

25 3. Impact to Transactional Documentation 24

26 Impact Do You on Have Your a Relationship FFI In Your Organization? with Your Bank What Your Financial Institution Will Ask you Financial Institution will need to determine FATCA status for each entity. Establish FATCA status by providing appropriate documentation: U.S. Legal Entities Form W-9 Non-U.S. Legal Entities Form W-8 or self certification and documentary evidence Request for additional documentation if US indicia are present Failure to provide appropriate documentation will result in 30% FATCA withholding and reporting. Impact on Transactional Documentation 25

27 Impact Do You on Have ISDA a FFI In Your Organization? ISDA Master Agreement Gross Up Provision: 2(d) (i) Gross Up. All payments under this Agreement will be made without any deduction or withholding for or on account of any Tax unless such deduction or withholding is required by any applicable law, as modified by the practice of any relevant governmental revenue authority, then in effect. If a Party is so required to deduct or withhold, then that party ( X ) will: (4) If such Tax is an Indemnifiable Tax, pay to Y, in addition to the payment to which Y is otherwise entitled under this Agreement, such additional amount as is necessary to ensure that the net amount actually received by Y (free and clear of Indemnifiable Taxes, whether assessed against X or Y) will equal the full amount Y would have received had no such deduction or withholding been required. However, X will not be required to pay any additional amount to Y to the extent that it would not be required to be paid but for :-- (A) the failure by Y to comply with or perform any agreement contained in Section 4(a)(i), 4(a)(iii) or 4(d); or (B) the failure of a representation made by Y pursuant to Section 3(f) to be accurate and true unless such failure would not have occurred but for (I) any action taken by a taxing authority, or brought in a court of competent jurisdiction, after a Transaction is entered into (regardless of whether such action is taken or brought with respect to a party to this Agreement) or (II) a Change in Tax Law. 26

28 Impact Do You on Have ISDA a FFI In Your Organization? ISDA FATCA Provision (August 15, 2012) Withholding Tax imposed on payments to non-us counterparties under the United States Foreign Account Tax Compliance Act. Tax as used in Part 2(a) of this Schedule (Payer Tax Representation) and Indemnifiable Tax as defined in Section 14 of this Agreement shall not include any U.S. federal withholding tax imposed or collected pursuant to Sections 1471 through 1474 of the U.S. Internal Revenue Code of 1986, as amended (the Code ), any current or future regulations or official interpretations thereof, any agreement entered into pursuant to Section 1471(b) of the Code, or any fiscal or regulatory legislation, rules or practices adopted pursuant to any intergovernmental agreement entered into in connection with the implementation of such Sections of the Code (a "FATCA Withholding Tax"). For the avoidance of doubt, a FATCA Withholding Tax is a Tax the deduction or withholding of which is required by applicable law for the purposes of Section 2(d) of this Agreement. Existing Master Agreements can be amended to include the ISDA FATCA Provision by adherence to the ISDA 2012 FATCA Protocol 27

29 What Does the ISDA Protocol Do? The Schedule to the ISDA Master Agreement generally contains a representation by the payor that it is not required to withhold any tax. The ISDA Master Agreement requires gross-up for withholding tax, thus putting economic burden on payor. The Protocol excludes FATCA withholding from the payor s tax representation. The main purpose of the 2012 ISDA FATCA Protocol ( Protocol ) is to place the economic burden of FATCA withholding, if any, on the payee by providing that FATCA withholding is not subject to grossup. The rationale behind the Protocol is that withholding, if any, is within the control of the payee because the payee could have avoided withholding by being FATCA compliant. The ISDA Master Agreement allows a payor to withhold from a payment that is required by law. For the avoidance of doubt, the Protocol states that FATCA withholding tax is a Tax the deduction of which is required by law. The markets have taken the position that the economic burden of FATCA should be borne by the payee since whether FATCA withholding occurs is within the control of the payee. The Protocol represents the approach of the markets in cross-border transactions. 28

30 The Effect of Entering into the Protocol The Protocol incorporates the changes described above into existing and future contracts with all other parties that have also adhered to the Protocol without the need for bilateral agreements to each confirmation made under an ISDA Master Agreement. Thus the protocol is the most efficient means of addressing FATCA withholding Currently, there is no cut-off date for entering the Protocol. 29

31 Impact on Syndicated Loan when Agent is Not Compliant Malaysian Bank US Corporation Korean Bank UK Bank Borrower (US*) Interest, fees and principal payments subject to withholding at 30% Agent (NPFFI) Singapore Bank Lenders (PFFIs) 30

32 Impact Do You on Have Loan a Agreements FFI In Your Organization? Loan Provisions from Loan Market Association Definition of FATCA Provision requiring the Parties to provide information to the other Parties relating to its FATCA status Right to withhold on account of FATCA Carve-out from Gross-up Example: The Borrower shall not be required to make an increased payment to a Finance Party under paragraph (a) above for (i) a Tax Deduction imposed by reason of such Finance Party s failure to comply with any certification, identification, information, documentation or other reporting requirement if such compliance is required by law, regulation, administrative practice or an applicable treaty as a precondition to exemption from, or reduction in the rate of, deduction or withholding of any Tax Deduction, (ii) a Tax Deduction imposed by reason of such Finance Party s failure to comply with Clause 14.7 or (iii) any U.S. federal income withholding tax imposed under FATCA. 31

33 Impact Do You on Have Offering a FFI Memorandum In Your Organization? Funds likely will have to disclose their FATCA status FATCA language will be included in offering documentation. Below is an example: We intend to structure our investments so that we will not be required to withhold 30% FATCA withholding tax earlier than 2017 although no assurances can be given in this regard. Pursuant to the FFI Agreement we intend to enter into, beginning no earlier than 2017, we will be required to withhold 30% FATCA withholding tax on certain dividends that we pay to foreign financial institutions that have not entered into an FFI Agreement (including [Name of Depository]) if it does not enter into an FFI Agreement) or to Shareholders that do not verify their status under the FATCA rules, to the extent such dividends are foreign passthru payments. The application of FATCA to an investment in our Shares will depend on: whether the foreign financial institutions through which you hold our Shares, including [name of depository] and any broker, have entered an FFI Agreement, which is outside of our control; and whether you verify your status under the FATCA rules to us or to the foreign financial institution through which you hold our Shares. 32

34 4. Intergovernmental Agreements 33

35 FATCA Intergovernmental Agreements Local law conflicts were the immediate reason that Treasury developed the IGA framework. FFIs in some jurisdictions found that they were unable as a legal matter to report information required under FATCA to the IRS, and IGAs were intended to address that problem. Coordination of the IGAs with the FATCA regulations was necessary to avoid a situation in which one FFI that operated in multiple jurisdictions that included IGA signatories and non-iga countries had different documentation requirements for each. Announcement on February 8, 2012 by the United States and 5 European countries of their intent to work together to develop an intergovernmental approach to improving international tax compliance and implementing FATCA. The countries that have publicly announced their interest for Model 1 were Germany, France, Italy, Spain, the U.K. and Ireland. Willing countries would enter into a bilateral agreement with the United States under which the foreign country would become a FATCA Partner in exchange for certain concessions by the U.S. Model 1 bilateral agreement published in July 2012 and Model II published in November As of February 2014, twenty-two IGA Agreements have been executed UK, Denmark, Germany, Ireland, Italy, Japan, Mexico, Norway, Spain, Switzerland, Bermuda, Malta, Netherlands, Guernsey, the Isle of Man, Jersey, Cayman Islands, Costa Rica, France, Canada, Hungary and Mauritius. Several others have been initialed, meaning all terms have been agreed to, the IGA has just not yet been signed. Still waiting for Hong Kong, Singapore, China and Malaysia agreements. 34

36 Structure of IGAs Agreement on definitions and obligations US Treasury has published Model IGAs Annex 1 on due diligence obligations for identifying and reporting on US accounts and certain payments Annex II identifies types of institutions and accounts that are exempt from reporting requirements ( Nonreporting FIs ) Contains a country specific list of exempt beneficial owners (i.e., government and supranational organizations) deemed-compliant FFIs (Non-reporting FIs and Collective Investment Vehicles), and exempt products or accounts (are not financial accounts) 35

37 Local Legal Issues FATCA imposes obligations on FFIs that may be in conflict with the laws of the jurisdiction in which an FFI operates, including Privacy laws prohibiting the sharing of personal information on clients, including sharing with a foreign tax authority Access-to-banking laws that guarantee that an account must be opened or that accounts may not be closed unilaterally Laws prohibiting the withholding of taxes for a foreign government or withholding without clients consent The IGAs present an opportunity for a country to support its FFIs compliance with FATCA by Changing local laws to remove legal obstacles to FATCA compliance Accepting the U.S. offer in the IGAs to modify or eliminate certain FFIs obligations that would apply under the Final FATCA Regulations 36

38 Benefits /Purposes of IGA True government to government agreement whereby involvement of government at inception. More authority to negotiate. Sovereignty control over information being exchanged (Model 1) Demonstrate commitment by the government to tackle tax evasion which is a developing global trend Establish uniform reporting standards and an automatic information exchange Competitiveness neighbouring countries are exploring IGA Typically eliminate local legal obstacles to FATCA compliance (Model 1) Reciprocity Lifting costly compliance burden from local financial institutions Generally, eliminates or reduces U.S. regulatory requirements for an FFI to: Enter into an FFI agreement with the IRS Withhold on payments made to FIs located in any Partner Country Withhold on payments made to recalcitrant accounts or close the accounts Once a country enters into a IGA, all financial institutions in that country are regarded as participating. More time for financial institution to register and design compliance programme. 37

39 Overview of Model 1 Reporting 38

40 Information Reporting by FATCA Partner FIs Report U.S. account holders who are: Specified U.S. persons, Non-U.S. entities having at least 1 controlling person that is a specified U.S. person A specified U.S. person is generally means any U.S. person other than an exempt recipient (but includes a privately held corporation that is not a related entity) Reportable information Name, address and TIN of each specified U.S. person Name, address and TIN (if any) of a non-us entity with at controlling specified U.S. person Account number Account balance or value at year end or account closing date Total gross interest, dividends, other income, gross proceeds from sale or redemption of property paid or credited to the account Form 8966 will be used by FFIs in reporting on U.S. accounts FATCA Partners in Model 2 countries must report annually the aggregate information required respecting U.S. accounts that do not consent to reporting 39

41 5.Timelines / What To Do Next 40

42 Timelines Phased implementation starting in 2014, and ending no earlier than 2017 Some systems and procedures need to be ready on July 1, 2014 Major key dates: First Sign Up For FFI Agreements: portal open now-- FFI Agreements start taking effect on July 1, Initial List of FFIs: To be Published on June 2, New Accounts: July 1, 2014 Grandfathering: July 1, 2014 Withholding: Begins July 1, 2014 for U.S. source income paid to certain payees (new accounts and preexisting accounts of known recalcitrant account holders and non-participating FFIs ( NPFFI )) and then phases in for additional tiers of payees in 2015 and 2016 gross proceeds and foreign passthru payment withholding can begin in 2017 although the Regulations reserve on those rules for now. Reporting: U.S. account reporting begins March 31, 2015 for the 2014 year 41

43 Action Points What to Do Next Understand the Regulations and move towards to compliance Form a project team Engage outside advisors Scope Survey /Diagnostic Survey Impact Analysis /Gap Analysis Implementation Plan Work with Government by responding to any questionnaire or surveys on IGA/FATCA Industry groups to work on list on products and entities to be included in Annex II Identify the impact on your financial institution if your country is unable to enter into an IGA by July 1, 2014 Understand the intention of your counterparties whether they will continue doing business with limited financial institutions 42

44 6. Questions and Answers 43

45 Thank You 44

46 IRS Circular 230 Disclosure: Citigroup Inc. and its affiliates do not provide tax or legal advice. Any discussion of tax matters in these materials (i) is not intended or written to be used, and cannot be used or relied upon, by you for the purpose of avoiding any tax penalties and (ii) may have been written in connection with the "promotion or marketing" of any transaction contemplated hereby ("Transaction"). Accordingly, you should seek advice based on your particular circumstances from an independent tax advisor. Any terms set forth herein are intended for discussion purposes only and are subject to the final terms as set forth in separate definitive written agreements. This presentation is not a commitment to lend, syndicate a financing, underwrite or purchase securities, or commit capital nor does it obligate us to enter into such a commitment, nor are we acting as a fiduciary to you. By accepting this presentation, subject to applicable law or regulation, you agree to keep confidential the information contained herein and the existence of and proposed terms for any Transaction. Prior to entering into any Transaction, you should determine, without reliance upon us or our affiliates, the economic risks and merits (and independently determine that you are able to assume these risks) as well as the legal, tax and accounting characterizations and consequences of any such Transaction. In this regard, by accepting this presentation, you acknowledge that (a) we are not in the business of providing (and you are not relying on us for) legal, tax or accounting advice, (b) there may be legal, tax or accounting risks associated with any Transaction, (c) you should receive (and rely on) separate and qualified legal, tax and accounting advice and (d) you should apprise senior management in your organization as to such legal, tax and accounting advice (and any risks associated with any Transaction) and our disclaimer as to these matters. By acceptance of these materials, you and we hereby agree that from the commencement of discussions with respect to any Transaction, and notwithstanding any other provision in this presentation, we hereby confirm that no participant in any Transaction shall be limited from disclosing the U.S. tax treatment or U.S. tax structure of such Transaction. We are required to obtain, verify and record certain information that identifies each entity that enters into a formal business relationship with us. We will ask for your complete name, street address, and taxpayer ID number. We may also request corporate formation documents, or other forms of identification, to verify information provided. Any prices or levels contained herein are preliminary and indicative only and do not represent bids or offers. These indications are provided solely for your information and consideration, are subject to change at any time without notice and are not intended as a solicitation with respect to the purchase or sale of any instrument. The information contained in this presentation may include results of analyses from a quantitative model which represent potential future events that may or may not be realized, and is not a complete analysis of every material fact representing any product. Any estimates included herein constitute our judgment as of the date hereof and are subject to change without any notice. We and/or our affiliates may make a market in these instruments for our customers and for our own account. Accordingly, we may have a position in any such instrument at any time. Although this material may contain publicly available information about Citi corporate bond research, fixed income strategy or economic and market analysis, Citi policy (i) prohibits employees from offering, directly or indirectly, a favorable or negative research opinion or offering to change an opinion as consideration or inducement for the receipt of business or for compensation; and (ii) prohibits analysts from being compensated for specific recommendations or views contained in research reports. So as to reduce the potential for conflicts of interest, as well as to reduce any appearance of conflicts of interest, Citi has enacted policies and procedures designed to limit communications between its investment banking and research personnel to specifically prescribed circumstances. [TRADEMARK SIGNOFF: add the appropriate signoff for the relevant legal vehicle] 2012 Citigroup Global Markets Inc. Member SIPC. All rights reserved. Citi and Citi and Arc Design are trademarks and service marks of Citigroup Inc. or its affiliates and are used and registered throughout the world Citigroup Global Markets Limited. Authorized and regulated by the Financial Services Authority. All rights reserved. Citi and Citi and Arc Design are trademarks and service marks of Citigroup Inc. or its affiliates and are used and registered throughout the world Citibank, N.A. All rights reserved. Citi and Citi and Arc Design are trademarks and service marks of Citigroup Inc. or its affiliates and are used and registered throughout the world Citigroup Inc. All rights reserved. Citi and Citi and Arc Design are trademarks and service marks of Citigroup Inc. or its affiliates and are used and registered throughout the world [Name of Legal Vehicle] [Name of regulatory body.] All rights reserved. Citi and Citi and Arc Design are trademarks and service marks of Citigroup Inc. or its affiliates and are used and registered throughout the world. Citi believes that sustainability is good business practice. We work closely with our clients, peer financial institutions, NGOs and other partners to finance solutions to climate change, develop industry standards, reduce our own environmental footprint, and engage with stakeholders to advance shared learning and solutions. Highlights of Citi s unique role in promoting sustainability include: (a) releasing in 2007 a Climate Change Position Statement, the first US financial institution to do so; (b) targeting $50 billion over 10 years to address global climate change: includes significant increases in investment and financing of renewable energy, clean technology, and other carbon-emission reduction activities; (c) committing to an absolute reduction in GHG emissions of all Citi owned and leased properties around the world by 10% by 2011; (d) purchasing more than 234,000 MWh of carbon neutral power for our operations over the last three years; (e) establishing in 2008 the Carbon Principles; a framework for banks and their U.S. power clients to evaluate and address carbon risks in the financing of electric power projects; (f) producing equity research related to climate issues that helps to inform investors on risks and opportunities associated with the issue; and (g) engaging with a broad range of stakeholders on the issue of climate change to help advance understanding and solutions. Citi works with its clients in greenhouse gas intensive industries to evaluate emerging risks from climate change and, where appropriate, to mitigate those risks. efficiency, renewable energy and mitigation 45

US FATCA FAQ and Glossary of FATCA terms

US FATCA FAQ and Glossary of FATCA terms US FATCA FAQ and Glossary of FATCA terms These FAQs are intended to aid you in your understanding how FATCA affects your relationship with UBS. This is not intended as tax advice. If you are uncertain

More information

FATCA The Foreign Account Tax Compliance Act

FATCA The Foreign Account Tax Compliance Act FATCA The Foreign Account Tax Compliance Act July 2012 July 2012 Table of Contents 1. Classification 2 2. Due Diligence 7 3. Withholding Payments 14 4. Reporting 21 What You Need to Take Away From This

More information

The Foreign Account Tax Compliance Act (FATCA)

The Foreign Account Tax Compliance Act (FATCA) The Foreign Account Tax Compliance Act (FATCA) Applying FATCA to Funds and other Collective Investment Vehicles Jonathan Sambur Partner + 1 202 263-3256 jsambur@mayerbrown.com February 2013 Mayer Brown

More information

SIGHT FATCA. line of FREQUENTLY ASKED QUESTIONS FOR FUND MANAGERS TABLE OF CONTENTS. July 2012 OVERVIEW... 2

SIGHT FATCA. line of FREQUENTLY ASKED QUESTIONS FOR FUND MANAGERS TABLE OF CONTENTS. July 2012 OVERVIEW... 2 line of SIGHT FATCA FREQUENTLY ASKED QUESTIONS FOR FUND MANAGERS TABLE OF CONTENTS July 2012 OVERVIEW... 2 NORTHERN TRUST S ROLES AND RESPONSIBILITIES... 7 PREVENTING FATCA WITHHOLDING... 8 A PARTICIPATING

More information

Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements

Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements - Regulatory Timeline - Overview of Requirements - Registration Process Naidira Alemova-Goeres

More information

T2S Dedicated Info Session on Getting Ready for Cross-CSD Settlements

T2S Dedicated Info Session on Getting Ready for Cross-CSD Settlements T2S Dedicated Info Session on Getting Ready for Cross-CSD Settlements Issue #2: Tax Processing Marcello Topa Citi Global Transaction Services EMEA 15/03/2012 Milan, Italy Issue #2: Tax Processing Scope

More information

Sight FATCA. line of. Frequently asked questions. table of contents. November 2, 2012

Sight FATCA. line of. Frequently asked questions. table of contents. November 2, 2012 line of Sight FATCA Frequently asked questions FOR INSTITUTIONAL INVESTORS table of contents November 2, 2012 PART I PROPOSED REGULATIONS and IRS Announcement OVERVIEW 1. What is the objective of the Foreign

More information

FATCA FAQs: Frequently asked questions on the Foreign Account Tax Compliance

FATCA FAQs: Frequently asked questions on the Foreign Account Tax Compliance www.pwc.com/us/fatca July 2011 FATCA FAQs: Frequently asked questions on the Foreign Account Tax Compliance Act 1. What is FATCA? FATCA is an acronym for The Foreign Account Tax Compliance Act (FATCA)

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) February 13, 2014 Spanish Chinese Russian Foreign Account Tax Compliance Act (FATCA) Introduction to FATCA and IGAs The Foreign Account Tax Compliance Act (FATCA) is a US law enacted in 2010 as part of

More information

The Impact of FATCA on U.S. and Non-U.S. Private Equity & Hedge Funds Closing the distance

The Impact of FATCA on U.S. and Non-U.S. Private Equity & Hedge Funds Closing the distance The Impact of FATCA on U.S. and Non-U.S. Private Equity & Hedge Funds Closing the distance Global Financial Services Industry Overview The Foreign Account Tax Compliance Act ( FATCA ) regime signifies

More information

PRESENTATION ON THE FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) FOR CONSULTATIONS WITH THE INDUSTRY

PRESENTATION ON THE FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) FOR CONSULTATIONS WITH THE INDUSTRY PRESENTATION ON THE FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) FOR CONSULTATIONS WITH THE INDUSTRY Prepared for the Meeting with ECCU Non-Bank Financial Institutions February 2014 EASTERN CARIBBEAN CENTRAL

More information

Centralizing Treasury in Latin America

Centralizing Treasury in Latin America Centralizing Treasury in Latin America Liquidity Perspectives Ron Chakravarti Managing Director Treasury Advisory Citi Treasury and Trade Solutions Treasury Models: Some Variations Group Treasury Local

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) Introduction As a global financial services organisation, it is necessary for Standard Bank to comply with the laws and regulations of many different authorities,

More information

Foreign Account Tax Compliance Act ( FATCA )

Foreign Account Tax Compliance Act ( FATCA ) Chio Lim Audit Tax Advisory Tax Update Foreign Account Tax Compliance Act ( FATCA ) 2 May 2014 Contacts: Cindy Lim Partner, International Tax Division T +65 6594 7852 cindylim@rsmchiolim.com.sg Chow Khen

More information

Citi Supplier Finance

Citi Supplier Finance Treasury & Trade Solutions North America Trade Finance Citi Supplier Finance Supplier Finance Program for UTC Suppliers The Solution UTC and Citi have entered into a partnership that enables preferred

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) What We Know and Don t Know Nicole Tanguy, Citi Phil Garlett, Burt, Staples & Maner LLP 11-12 July 2011 What is FATCA? The State of the Law New Chapter 4 of the

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) What We Know and Don t Know Nicole Tanguy, Citigroup Inc. November 30, 2011 What is FATCA? The State of the Law New Chapter 4 of the Internal Revenue Code (IRC)

More information

FATCA Regulations Training Session #3

FATCA Regulations Training Session #3 Transaction Services July 2013 FATCA Regulations Training Session #3 Update on Changes to New Account Due Diligence Based on Final Regulations Debbie Mercer-Miller Director and U.S. Securities Country

More information

WEXOnline Data Analysis and Reporting Tools

WEXOnline Data Analysis and Reporting Tools GSA SmartPay 2010 Conference WEXOnline Data Analysis and Reporting Tools Sharon Linnane Government Account Manager, Wright Express Corporation 12 th Annual GSA SmartPay Conference Atlanta, GA August 10-12,

More information

The Foreign Account Tax Compliance Act (FATCA)

The Foreign Account Tax Compliance Act (FATCA) The Foreign Account Tax Compliance Act (FATCA) I. OVERVIEW A. What is FATCA? FATCA, as it is colloquially known, refers to Chapter 4 of the US Internal Revenue Code, which was enacted by the Hiring Incentives

More information

Foreign Account Tax Compliance Act (FATCA) Frequently Asked Questions

Foreign Account Tax Compliance Act (FATCA) Frequently Asked Questions Foreign Account Tax Compliance Act (FATCA) Frequently Asked Questions For Momentum Retail (excluding Momentum Wealth International) General FATCA questions 1. What is FATCA? FATCA is the acronym for the

More information

This notice provides guidance to foreign financial institutions (FFIs) entering into

This notice provides guidance to foreign financial institutions (FFIs) entering into Part III Administrative, Procedural, and Miscellaneous FFI agreement for Participating FFI and Reporting Model 2 FFI Notice 2013-69 SECTION I. Purpose. This notice provides guidance to foreign financial

More information

IRS Issues Final FATCA Regulations

IRS Issues Final FATCA Regulations IRS Issues Final FATCA Regulations The United States Internal Revenue Service (IRS) has issued long-awaited final regulations (the Final Regulations) under the Foreign Account Tax Compliance Act (FATCA).

More information

FATCA and Insurance. Ninth Annual International Insurance Training Program

FATCA and Insurance. Ninth Annual International Insurance Training Program Ninth Annual International Insurance Training Program FATCA and Insurance Stewart Kasner, Baker & McKenzie LLP, Miami Lyubomir Georgiev, Baker & McKenzie Zurich Four Points by Sheraton Zurich, Switzerland

More information

CIPI Soundbite: CPO/CTA Registration & non-us Funds

CIPI Soundbite: CPO/CTA Registration & non-us Funds CIPI Soundbite: CPO/CTA Registration & non-us Funds Citibank International Plc, Ireland Branch October 2012 Glossary You must learn to talk clearly. The jargon of scientific terminology which rolls off

More information

Payment Factories: different ways of achieving payment efficiency. Jonathan Jordan EMEA Payments Market Manager, Citi Transaction Services

Payment Factories: different ways of achieving payment efficiency. Jonathan Jordan EMEA Payments Market Manager, Citi Transaction Services Payment Factories: different ways of achieving payment efficiency Jonathan Jordan EMEA Payments Market Manager, Citi Transaction Services The term Payment Factory is becoming increasingly talked about

More information

F.A.T.C.A. in a Nutshell: Questions and Answers to Tickle the Fancy of a Compliance Officer 1 By Fabien Gaglio and Stanley C.

F.A.T.C.A. in a Nutshell: Questions and Answers to Tickle the Fancy of a Compliance Officer 1 By Fabien Gaglio and Stanley C. F.A.T.C.A. in a Nutshell: Questions and Answers to Tickle the Fancy of a Compliance Officer 1 By Fabien Gaglio and Stanley C. Ruchelman The following F.A.Q. provides a general overview of the Foreign Account

More information

Key Aspects of the FATCA Regime

Key Aspects of the FATCA Regime TAX CLIENT PUBLICATION May 2012... Key Aspects of the FATCA Regime... The US withholding and information reporting regime under the Foreign Account Tax Compliance Act of 2010 ( FATCA ), 1 when implemented,

More information

Foreign Account Tax Compliance Act

Foreign Account Tax Compliance Act www.pwc.co.za Foreign Account Tax Compliance Act 7t h March 2012 An overview The Foreign Account Tax Compliance Act provisions which were included in the Hiring Incentives to Restore Employment ( HIRE

More information

Tax Initiatives The Common Reporting Standard

Tax Initiatives The Common Reporting Standard Treasury and Trade Solutions February 2016 Tax Initiatives The Common Reporting Standard The Common Reporting Standard (CRS) The Common Reporting Standard - Overview The Common Reporting Standard ( CRS

More information

Further Guidance on the Implementation of FATCA and Related Withholding Provisions

Further Guidance on the Implementation of FATCA and Related Withholding Provisions Further Guidance on the Implementation of FATCA and Related Withholding Provisions Notice 2014-33 I. PURPOSE This notice announces that calendar years 2014 and 2015 will be regarded as a transition period

More information

Insurance Authority Workshop Foreign Account Tax Compliance Act. Abu Dhabi 28 January 2014

Insurance Authority Workshop Foreign Account Tax Compliance Act. Abu Dhabi 28 January 2014 Insurance Authority Workshop Foreign Account Tax Compliance Act Abu Dhabi 28 January 2014 Agenda q q q q q q FATCA and IGAs FATCA Timeline Focus for next 6 months US Treasury and IRS update Matters Arising

More information

Citibank Custom Reporting System (CCRS) Cycle based Reporting

Citibank Custom Reporting System (CCRS) Cycle based Reporting GSA SmartPay 2010 Conference Citibank Custom Reporting System (CCRS) Cycle based Reporting Mini Session 12 th Annual GSA SmartPay Conference Atlanta, GA August 10 12, 2010 Goals and Objectives This course

More information

Global Tax Initiatives The Evolving Regulatory Environment

Global Tax Initiatives The Evolving Regulatory Environment Treasury and Trade Solutions March 2016 Global Tax Initiatives The Evolving Regulatory Environment Global Tax Initiatives The Regulatory Environment Local Governments Governments are continuing to coordinate

More information

Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014)

Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014) Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014) Section references are to the Internal Revenue Code unless otherwise noted. Future developments. For

More information

IRS releases updated QI agreement providing guidance for QIs under FATCA and Chapter 3

IRS releases updated QI agreement providing guidance for QIs under FATCA and Chapter 3 IRS releases updated QI agreement providing guidance for QIs under FATCA and Chapter 3 July 3, 2014 In brief On June 27, 2014, the Internal Revenue Service (IRS) released Revenue Procedure 2014-39 which

More information

Foreign Account Tax Compliance Act FATCA Onboarding Requirements for Payees U.S. Financial Institutions

Foreign Account Tax Compliance Act FATCA Onboarding Requirements for Payees U.S. Financial Institutions Paris New York London Rome Milan Casablanca Dubai Amsterdam Brussels Hong Kong Singapore Foreign Account Tax Compliance Act FATCA Onboarding Requirements for Payees U.S. Financial Institutions June 13,

More information

FOREIGN ACCOUNT TAX COMPLIANCE ACT ( FATCA ): COMPLIANCE TO ELIMINATE WITHHOLDING TAX. November 19, 2013

FOREIGN ACCOUNT TAX COMPLIANCE ACT ( FATCA ): COMPLIANCE TO ELIMINATE WITHHOLDING TAX. November 19, 2013 FOREIGN ACCOUNT TAX COMPLIANCE ACT ( FATCA ): COMPLIANCE TO ELIMINATE WITHHOLDING TAX November 19, 2013 MICHAEL HIRSCHFELD DECHERT LLP (212) 698-3635 michael.hirschfeld@dechert.com 12116187v1 1 FATCA Overview

More information

Preventing Misuse and Abuse in Your Program

Preventing Misuse and Abuse in Your Program GSA SmartPay Conference Preventing Misuse and Abuse in Your Program Maureen Garlock Vice President, Citi 11 th Annual GSA SmartPay Conference Phoenix, Arizona July 28 th - July 30 th, 2009 Preventing Misuse

More information

Agreement Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA

Agreement Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Agreement Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Whereas, Switzerland and the United States of America ( United States, each, a Party

More information

Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference

Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference Foreign Account Tax Compliance Act: Considerations for Trusts April 30, 2014 Michael Shepard Principal

More information

Citi s Affordable Housing Subordinate Loan Program

Citi s Affordable Housing Subordinate Loan Program Citi Community Capital August 19, 2014 Citi s Affordable Housing Subordinate Loan Program Citi s Affordable Housing Subordinate Loan Program Citi s Affordable Housing Subordinate Loan Program (the Program

More information

Issues Facing the Asset Management Industry. Navigating a Challenging Environment

Issues Facing the Asset Management Industry. Navigating a Challenging Environment Issues Facing the Asset Management Industry Navigating a Challenging Environment Top Issues Facing Asset Managers Primary challenges that Citi sees our asset manager clients facing Regulatory Complexity

More information

Foreign Account Tax Compliance Act ( FATCA )

Foreign Account Tax Compliance Act ( FATCA ) May 2011 Foreign Account Tax Compliance Act ( FATCA ) www.steptoe.com Table of Contents Overview Definition of Foreign Financial Institution ( FFI ) FFI Agreement with IRS Preexisting Individual Accounts

More information

Treasure Trove The Rising Role of Treasury in Accounts Payable

Treasure Trove The Rising Role of Treasury in Accounts Payable Treasury and Trade Solutions North America July 30, 2015 Treasure Trove The Rising Role of Treasury in Accounts Payable 2015 Citibank, N.A. All rights reserved Today s Speakers Andrew Bartolini Chief Research

More information

ACTION: Notice of proposed rulemaking and notice of public hearing. SUMMARY: This document contains proposed regulations under chapter 4 of

ACTION: Notice of proposed rulemaking and notice of public hearing. SUMMARY: This document contains proposed regulations under chapter 4 of [4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 301 [REG-121647-10] RIN 1545-BK68 Regulations Relating to Information Reporting by Foreign Financial Institutions and

More information

Understanding & Realizing Big Data Potential

Understanding & Realizing Big Data Potential Understanding & Realizing Big Data Potential 2014 Latin America Treasury & Finance Conference A Blueprint for a Digitally Connected Treasury Driss R. Temsamani Analytics & Innovation Head driss.r.temsamani@citi.com

More information

IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system

IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system What is FATCA? The Foreign Account Tax Compliance Act (FATCA) is a new

More information

US Foreign Account Tax Compliance Act Intergovernmental Agreement. Frequently Asked Questions

US Foreign Account Tax Compliance Act Intergovernmental Agreement. Frequently Asked Questions US Foreign Account Tax Compliance Act Intergovernmental Agreement Frequently Asked Questions This document aims to provide background information regarding the intergovernmental agreement ( IGA ) to be

More information

IRAS e-tax Guide. Compliance Requirements of the Singapore-US Intergovernmental Agreement on Foreign Account Tax Compliance Act

IRAS e-tax Guide. Compliance Requirements of the Singapore-US Intergovernmental Agreement on Foreign Account Tax Compliance Act IRAS e-tax Guide Compliance Requirements of the Singapore-US Intergovernmental Agreement on Foreign Account Tax Compliance Act Published by Inland Revenue Authority of Singapore Published on 17 Mar 2015

More information

FATCA Frequently Asked Questions

FATCA Frequently Asked Questions FATCA Frequently Asked Questions FATCA overview 1. What is FATCA? 2. What is the impact of FATCA? 3. How do I know if I am affected? 4. When will the FATCA legislation become effective? 5. Is HSBC the

More information

Dematerialization of Turkish Government Debt Instruments

Dematerialization of Turkish Government Debt Instruments Dematerialization of Turkish Government Debt Instruments Asli Gunel Central Registry Agency Gunsel Topbas Citibank A.S. Turkey 19 January 2012 1 Government Debt Instruments Quick Facts Central Bank of

More information

WHITE PAPER. Impact of FATCA on Client Onboarding Achieve FATCA compliance with effective, result-oriented IT and operational changes.

WHITE PAPER. Impact of FATCA on Client Onboarding Achieve FATCA compliance with effective, result-oriented IT and operational changes. WHITE PAPER Impact of FATCA on Client Onboarding Achieve FATCA compliance with effective, result-oriented IT and operational changes Abstract In March 2010, the Foreign Account Tax Compliance Act (FATCA)

More information

TAXATION (INTERNATIONAL TAX COMPLIANCE) (CROWN DEPENDENCY [CD]) REGULATIONS 2014 GUIDANCE NOTES. RELEASE DATE: 1 April 2014

TAXATION (INTERNATIONAL TAX COMPLIANCE) (CROWN DEPENDENCY [CD]) REGULATIONS 2014 GUIDANCE NOTES. RELEASE DATE: 1 April 2014 TAXATION (INTERNATIONAL TAX COMPLIANCE) (CROWN DEPENDENCY [CD]) REGULATIONS 2014 GUIDANCE NOTES RELEASE DATE: 1 April 2014 Note : These draft Guidance Notes dated 1 April 2014 have been revised to reflect

More information

Agreement 1 Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA

Agreement 1 Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Agreement 1 Between Switzerland and the United States of America for Cooperation to Facilitate the Implementation of FATCA Whereas, Switzerland and the United States of America ( United States, each, a

More information

Cayman Islands Financial Account Reporting for Investment Funds What Must Be Done, By When?

Cayman Islands Financial Account Reporting for Investment Funds What Must Be Done, By When? ealert November 2014 Cayman Islands Financial Account Reporting for Investment Funds What Must Be Done, By When? The Cayman Islands currently has in place an intergovernmental agreement (IGA) with each

More information

Advanced Management and Delinquency Reporting Hands On

Advanced Management and Delinquency Reporting Hands On GSA SmartPay 2010 Conference Advanced Management and Delinquency Reporting Hands On Tony Swann & Rob Robbins Training & Account Management 12 th Annual GSA SmartPay Conference Atlanta, GA August 10-12,

More information

F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S

F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S S T R I C T L Y P R I V A T E A N D C O N F I D E N T I A L F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S J.P. Morgan Corporate & Investment Bank Presented

More information

Simplified Instructions for Completing a Form W-8BEN-E

Simplified Instructions for Completing a Form W-8BEN-E Simplified Instructions for Completing a Form W-8BEN-E For Non-Financial Institutions Only Updated April 2015 Circular 230 Disclaimer: Any tax advice contained in this communication is not intended or

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) FATCA REGISTRATION GUIDANCE NOTES Issued by Inland Revenue, New Zealand 30 July 2014 Version 1.4 [Note: These Guidance Notes replace version 1.3, dated 13 January

More information

Analysis of FATCA Regulations for Foreign Financial Institutions

Analysis of FATCA Regulations for Foreign Financial Institutions Analysis of FATCA Regulations for Foreign Financial Institutions Withholding, Information Reporting February 2014 kpmg.com FATCA - Regulations on information reporting by foreign financial institutions;

More information

What s New in Citi s Online Tools

What s New in Citi s Online Tools GSA SmartPay 2010 Conference What s New in Citi s Online Tools David Lipke Citi Product Development 12 th Annual GSA SmartPay Conference Atlanta, GA August 10 12, 2010 House Rules To ensure the best possible

More information

Frequently Asked Questions (FAQ) FATCA

Frequently Asked Questions (FAQ) FATCA Frequently Asked Questions (FAQ) FATCA Table of Contents General... 3 What is FATCA?... 3 What is the purpose of FATCA?... 3 When does FATCA begin?... 3 Who is impacted by FATCA?... 3 What information

More information

Client Delivery TAMPA

Client Delivery TAMPA Treasury and Trade Solutions April, 10 th 2015 Client Delivery TAMPA Patricia Pires Citi Service Center and Offshore Unit Head for Latin America Agenda Quién somos nosotros? Nuestra Estructura Nuestros

More information

Program Audit Tool (Reporting Solution)

Program Audit Tool (Reporting Solution) 2011 GSA SmartPay Training Conference Program Audit Tool (Reporting Solution) Heelay Yaftali Vice President, Citi A Winning Hand: Solutions, Savings and Sustainability with GSA SmartPay The 13 th Annual

More information

FATCA Overview for Non-U.S. Insurance Companies

FATCA Overview for Non-U.S. Insurance Companies Stewart Patton U.S. Tax Services P.O. Box 2651 Belize City, Belize www.ustax.bz +501 610-0689 (Belize phone number) (312) 675-8571 (U.S. VOIP number) stewart.patton1 (Skype ID) stewart@ustax.bz FATCA Overview

More information

GUIDANCE NOTES ON THE IMPLEMENTATION OF FATCA IN IRELAND

GUIDANCE NOTES ON THE IMPLEMENTATION OF FATCA IN IRELAND GUIDANCE NOTES ON THE IMPLEMENTATION OF FATCA IN IRELAND While every effort is made to ensure that the information given in this guide is accurate, it is not a legal document. Responsibility cannot be

More information

Treasury and Trade Services Global Payments. Citi Payment Analytics User Guide

Treasury and Trade Services Global Payments. Citi Payment Analytics User Guide Treasury and Trade Services Global Payments Citi Payment Analytics User Guide Table of Contents 1. Accessing Payment Analytics 2. Dashboard Overview Getting to the Citi Payment Analytics Dashboard Overview

More information

The widespread reach of FATCA How will it affect your business?

The widespread reach of FATCA How will it affect your business? www.pwc.com/us/fatca The widespread reach of FATCA How will it affect your business? August 2013 Contents The short answer 1 Now is the right time to learn more and take action 2 What are some specific

More information

BECS Pre-Trade Analytics. An Overview

BECS Pre-Trade Analytics. An Overview BECS Pre-Trade Analytics An Overview January 2010 Citi s Pre-Trade Analytical Products and Services Citi has a long history of providing advanced analytical tools to our clients. Significant effort has

More information

FATCA for Multinational Companies

FATCA for Multinational Companies FATCA for Multinational Companies Alan J. Schwartz February 27, 2015 www.mwe.com Boston Brussels Chicago Düsseldorf Frankfurt Houston London Los Angeles Miami Milan Munich New York Orange County Paris

More information

GSA SmartPay Conference. Credit Card Basics. Bruce E. Sullivan VP / Head of Specialized Sales - Federal, Visa, Inc.

GSA SmartPay Conference. Credit Card Basics. Bruce E. Sullivan VP / Head of Specialized Sales - Federal, Visa, Inc. GSA SmartPay Conference Credit Card Basics Bruce E. Sullivan VP / Head of Specialized Sales - Federal, Visa, Inc. 11 th Annual GSA SmartPay Conference Phoenix, Arizona July 28 th - July 30 th, 2009 Credit

More information

FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA)

FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) CUSTOMERFREQUENTLY ASKED QUESTIONS What exactly is FATCA? FATCA is rapidly becoming the global model for combating offshore tax evasion and promoting transparency. FATCA is an acronym for the United States

More information

Implementing a Program Management Plan

Implementing a Program Management Plan GSA SmartPay 2010 Conference Implementing a Program Management Plan Heelay Yaftali Vice President 12 th Annual GSA SmartPay Conference Atlanta, GA August 10-12, 2010 House Rules To ensure the best possible

More information

[Mutual Legal Assistance (Tax Matters) Act, 2003 (as amended)] British Virgin Islands RELEASE DATE: [ ] JULY 2014

[Mutual Legal Assistance (Tax Matters) Act, 2003 (as amended)] British Virgin Islands RELEASE DATE: [ ] JULY 2014 This document is a DRAFT of the proposed Guidance Notes for the US and UK FATCA Agreements with the Government of the British Virgin Islands and at this stage it is for discussion purposes ONLY! [Mutual

More information

GSA SmartPay 2010 Conference. Disputes: DoD Travel. Karen Young Senior Vice President, Citi

GSA SmartPay 2010 Conference. Disputes: DoD Travel. Karen Young Senior Vice President, Citi GSA SmartPay 2010 Conference Disputes: Karen Young Senior Vice President, Citi 12 th Annual GSA SmartPay Conference Atlanta, GA August 10-12, 2010 House Rules To ensure the best possible learning experience

More information

Spotlight on the US. Christopher Brown US Tax Desk, KPMG In the UK

Spotlight on the US. Christopher Brown US Tax Desk, KPMG In the UK Spotlight on the US Christopher Brown US Tax Desk, KPMG In the UK 24 June 2016 Agenda 1 2 3 4 5 6 7 8 FATCA: An overview Definition of FIs under FATCA FATCA reportable accounts and account holders Remediation

More information

Kuwait Stock Exchange. New Changes and Implementations

Kuwait Stock Exchange. New Changes and Implementations Kuwait Stock Exchange New Changes and Implementations May 2012 Table of Contents 1. Old and New systems 4 2. New Trading System X-stream 8 3. Sector Classification 11 4. Kuwait 15 Index 13 5. New Website

More information

VEDDERPRICE Chicago New York Washington, DC London San Francisco Los Angeles. FATCA for Private Funds: Key Considerations

VEDDERPRICE Chicago New York Washington, DC London San Francisco Los Angeles. FATCA for Private Funds: Key Considerations VEDDERPRICE Chicago New York Washington, DC London San Francisco Los Angeles August 2014 FATCA for Private Funds: Key Considerations Although the Foreign Account Tax Compliance Act (FATCA) went live July

More information

Version 3.0 (29.07.2014) Table of Contents

Version 3.0 (29.07.2014) Table of Contents Guidelines for the implementation of the FATCA Agreement and the FATCA Regulations in Malta issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) Version 3.0 (29.07.2014)

More information

FATCA -- Overview and Onboarding

FATCA -- Overview and Onboarding IIB Annual Seminar on U.S. Taxation of International Banks June 17-18, 2014 FATCA -- Overview and Onboarding Chip Collins, UBS AG (Moderator) John Sweeney, IRS Tara Ferris, IRS Jon Lakritz, PwC Danielle

More information

FATCA Q & A Issue 12 Luxembourg, April 15thMay 6th, 2014

FATCA Q & A Issue 12 Luxembourg, April 15thMay 6th, 2014 Q & A Issue 12 Luxembourg, April 15thMay 6 th, 2014 Important This Q&A document was prepared by ALFI's implementation working groups for the U.S. Foreign Account Tax Compliance Act (). The working groups

More information

Agreement Between the United States of America and the Kingdom of Spain to Improve International Tax Compliance and to Implement FATCA

Agreement Between the United States of America and the Kingdom of Spain to Improve International Tax Compliance and to Implement FATCA Agreement Between the United States of America and the Kingdom of Spain to Improve International Tax Compliance and to Implement FATCA Whereas, the United States of America and the Kingdom of Spain (each,

More information

Using CitiManager Card Management Module Travel

Using CitiManager Card Management Module Travel 2011 GSA SmartPay Training Conference Using CitiManager Card Management Module Travel Instructor s Name Instructor s Title, Citi A Winning Hand: Solutions, Savings and Sustainability with GSA SmartPay

More information

Whereas, the Government of the Republic of Poland is supportive of the underlying policy goal of FATCA to improve tax compliance;

Whereas, the Government of the Republic of Poland is supportive of the underlying policy goal of FATCA to improve tax compliance; Agreement between the Government of the Republic of Poland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA Whereas, the Government of the

More information

IRS Releases Updated Qualified Intermediary (QI) Agreement

IRS Releases Updated Qualified Intermediary (QI) Agreement International Bank Tax Newsletter IRS Releases Updated Qualified Intermediary (QI) Agreement Authored by Melinda T. Schmidt On June 27, 2014, the Internal Revenue Service (IRS) released Revenue Procedure

More information

Tax Group Client Alert

Tax Group Client Alert Tax Group Client Alert For Beijing Frankfurt Hong Kong London Los Angeles Munich New York São Paulo Singapore Tokyo Washington, DC FATCA 2.0 FOR FUNDS AND SECURITIZATION VEHICLES Introduction On February

More information

UPDATED INFORMATION ON USE OF FORM W-8IMY (REVISION DATE FEBRUARY 2006) BEFORE JANUARY 1, 2015

UPDATED INFORMATION ON USE OF FORM W-8IMY (REVISION DATE FEBRUARY 2006) BEFORE JANUARY 1, 2015 UPDATED INFORMATION ON USE OF FORM W-8IMY (REVISION DATE FEBRUARY 2006) BEFORE JANUARY 1, 2015 This Form W-8IMY (revision date April 2014) reflects the changes made in the Foreign Account Tax Compliance

More information

A Comprehensive FATCA Solution

A Comprehensive FATCA Solution in collaboration with A Comprehensive FATCA Solution End-to-end automated legal, technology and software solution facilitates global compliance with U.S. Foreign Account Tax Compliance Act requirements

More information

How does the recent FATCA guidance affect asset managers?

How does the recent FATCA guidance affect asset managers? from Asset Management How does the recent FATCA guidance affect asset managers? April 10, 2014 In brief On February 20, 2014, the US Department of the Treasury (Treasury) and the Internal Revenue Service

More information

FATCA for non-financial companies What you don't know may hurt you

FATCA for non-financial companies What you don't know may hurt you FATCA for non-financial companies What you don't know may hurt you Anthony Martirano Jr., Deloitte Tax LLP December 6, 2012 FATCA overview FATCA aims to identify U.S. persons trying to avoid U.S. tax obligations

More information

Agreement between the United States of America and the Kingdom of the Netherlands to Improve International Tax Compliance and to Implement FATCA

Agreement between the United States of America and the Kingdom of the Netherlands to Improve International Tax Compliance and to Implement FATCA Agreement between the United States of America and the Kingdom of the Netherlands to Improve International Tax Compliance and to Implement FATCA Whereas, the United States of America and the Kingdom of

More information

TAXATION (INTERNATIONAL TAX COMPLIANCE) (JERSEY) REGULATIONS 2014 DRAFT GUIDANCE NOTES. RELEASE DATE: 9 Sept 2015

TAXATION (INTERNATIONAL TAX COMPLIANCE) (JERSEY) REGULATIONS 2014 DRAFT GUIDANCE NOTES. RELEASE DATE: 9 Sept 2015 TAXATION (INTERNATIONAL TAX COMPLIANCE) (JERSEY) REGULATIONS 2014 DRAFT GUIDANCE NOTES RELEASE DATE: 9 Sept 2015 Note : The Draft Guidance Notes have been further revised in response to requests from interested

More information

Agency Update: Hear the News from the Top

Agency Update: Hear the News from the Top Market insights on Community Development Agency Update February 18, 2014 Agency Update: Hear the News from the Top Woody Brewer from Fannie Mae and Kim Griffith from Freddie Mac Share Their Views Woody

More information

U.S. Tax Services Stewart H. Patton 610-0689 stewart@ustax.bz. FATCA Overview. March 2014

U.S. Tax Services Stewart H. Patton 610-0689 stewart@ustax.bz. FATCA Overview. March 2014 U.S. Tax Services Stewart H. Patton 610-0689 stewart@ustax.bz FATCA Overview March 2014 FATCA Terminology FATCA: The U.S. Foreign Account Tax Compliance Act, added by the HIRE Act of 2010. FATCA added

More information

FATCA Pre-Existing Accounts v. Onboarding: Clarifying the Differences. June 27, 2012

FATCA Pre-Existing Accounts v. Onboarding: Clarifying the Differences. June 27, 2012 FATCA Pre-Existing Accounts v. Onboarding: Clarifying the Differences June 27, 2012 Agenda Introduction Presentation Questions and Answers (anonymous) Slides now available on front page of Securities Docket

More information

The Benefits of Moving from Fragmented to Integrated Cash Application

The Benefits of Moving from Fragmented to Integrated Cash Application The Benefits of Moving from Fragmented to Integrated Cash Application Basak Toprak, EMEA Market Manager for Receivables and Channel Services, Global Transaction Services, Citi Frank Gastl, MD of Hanse

More information

The IRS Issues Final FATCA Regulations

The IRS Issues Final FATCA Regulations The IRS Issues Final FATCA Regulations On January 17, 2013, the Internal Revenue Service (IRS) released 544 pages of final regulations implementing the provisions of the Foreign Account Tax Compliance

More information

Global IRW Newsbrief Information reporting and withholding (IRW)

Global IRW Newsbrief Information reporting and withholding (IRW) www.pwc.com Global IRW Newsbrief Information reporting and withholding (IRW) February 27, 2012 The new proposed FATCA regulations: Overview On October 27, 2009, members of the U.S. Senate Finance Committee

More information

GUIDANCE NOTES ON THE IMPLEMENTATION OF FATCA IN IRELAND

GUIDANCE NOTES ON THE IMPLEMENTATION OF FATCA IN IRELAND GUIDANCE NOTES ON THE IMPLEMENTATION OF FATCA IN IRELAND While every effort is made to ensure that the information given in this guide is accurate, it is not a legal document. Responsibility cannot be

More information