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

Size: px
Start display at page:

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

Transcription

1 Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement Model 1 Latest Updates and Requirements - Regulatory Timeline - Overview of Requirements - Registration Process Naidira Alemova-Goeres Partner, Deloitte Financial Advisory GmbH Bucharest, October 3, 2013

2 FATCA aims to identify from US persons trying to avoid US tax obligations by holding assets in non-us structures and products FATCA US Person $ What does FATCA involve? Foreign Financial Institutions (FFIs) are required to enter agreements with U.S. Treasury to identify and report U.S. accounts annually Non-Financial Foreign Entities (NFFEs) are required to report substantial U.S. owners or certify no U.S. ownership U.S. withholding agents and participating FFIs are required to withhold 30% of withholdable payments made to recalcitrant account holders or non-participating FFIs. IFA / wealth manager Bank account Fund Custodian $ US Assets Trust U.S. Withholding Broker Agents, FFIs and NFFEs Insurance product Income, sales proceeds and passthru payments Participating FFIs are required to select FFI Officers who certify that the FFI is in compliance with the obligations set forth under the agreement. Who must meet the FATCA requirements? Foreign Financial Institutions Non-Foreign Financial Entities and affiliates U.S. Withholding Agents Who are the targets? U.S. Individuals U.S. Entities ( including corporations, partnerships and trusts ) Non-U.S. Financial Entities with substantial U.S. ownership 1

3 Chronological Development On January 17, 2013, the U.S. Treasury Department ( Treasury ) and the Internal Revenue Service ( IRS ) issue final FATCA regulations ( Final Regulations ) Originally codified as part of the Hiring Incentives to Restore Employment Act of 2010, the Final Regulations complete a series of interim guidance issued by the Treasury and the IRS, including a series of IRS notices, the proposed regulations released on February 8, 2012, and Notice issued on October 24, Notice , issued by the IRS on July 12, 2013, provided new timelines for the implementation of the requirements: in accordance with the revised timelines, foreign financial institutions ( FFIs ) shall prepare for the first wave of compliance milestones starting July 1, The Final Regulations introduce the Global Intermediary Identification Number (GIIN) and place great emphasis on the relationship of the regulations with the two forms of intergovernmental agreements ( IGAs ): Model 1 and Model 2. In particular, the Final Regulations make clear that FFIs in Model 1 IGA jurisdictions will be governed by the laws enacted in their own countries while those in Model 2 IGA jurisdictions will follow the final regulations. The Final Regulations do leave open the opportunity for foreign governments to negotiate for the inclusion of terms that would allow entities within their jurisdiction to follow more beneficial requirements in the Final Regulations. The emphasis on IGAs may signify Treasury s realization that IGAs and not the Final Regulations may be the path forward to achieve FATCA s goal and establish a global information reporting framework. 2

4 Updated Timeline Summary: Final Regulations vs. Notice FATCA Compliance Action Items Old Date New Date Registration Portal Opening Date July 15, 2013 August 19, 2013 GIIN Registration Deadline for first 2014 list October 25, 2013 April 25, 2014 General Compliance First 2014 GIIN list December 2, 2013 June 2, 2014 Last date to register for GIIN before withholding begins 1 December 31, June 30, Effective date of FFI Agreement for registrations before December 31, withholding begins June 30, 2014 Transition Period for affiliated group rule January 1, 2016 No Change FFI begin new client account onboarding January 1, 2014 July 1, 2014 Cutoff date to determine preexisting account population December 31, 2013 June 30, 2014 New / Preexisting Accounts Initial account balance determination date for deminimis rules and high value account 3 rule December 31, 2013 FFI complete preexisting Prima Facie FFI accounts 2 June 30, 2014 FFI complete preexisting high value individual accounts FFI complete all other preexisting entity accounts FFI complete all other preexisting individual accounts December 31, 2014 December 31, 2015 December 31, 2015 June 30, 2014 December 31, 2014 June 30, 2015 June 30, 2016 June 30,

5 Updated Timeline Summary: Final Regulations vs. Notice (continued) FATCA Compliance Action Items Old Date New Date Reporting Calendar year(s) to report for U.S. Account reporting 2013 & (for U.S. account identified by December 31, 2014) Begin income withholding on U.S. source FDAP 4 income for Nonparticipating FFIs 5 January 1, 2014 July 1, 2014 Withholding Begin offshore U.S. source income payment withholding 2 January 1, 2017 No Change Begin gross proceeds withholding 2 January 1, 2017 No Change Begin foreign -passthru payments withholding 2 January 1, 2017 No Change 1 Verification of a GIIN is not required for a Model 1 FFI prior to January 1, Model 1 FFIs will be able to register and obtain a GIIN beginning on January 1, 2014 but will have additional time beyond July 1, 2014 to register and obtain a GIIN to be included in the FFI list before January 1, Not applicable to Model 1 FFIs. 3 Preexisting individual accounts with a balance or value that exceeds $1,000,000 as of December 31, Payments of U.S. source dividends, interest and other fixed or determinable annual or periodic income. 5 Applies to U.S. source income paid to Nonparticipating FFIs by reporting FATCA Partner Financial Institutions acting as a withholding Qualified Intermediary ( QI ), withholding foreign partnership or withholding foreign trust. Other reporting FATCA Financial Institutions must provide information necessary to allow an immediate payor to withhold. 4

6 IGA Model 1Customer Due Diligence: New Individual & Entity accounts Model 1 IGA Final Regulations Request self-certification from each Individual and Entity account holder to establish the account holder U.S. status Rely on documentation collected for KYC/AML purposes Confirm the reasonableness of the self certification based on the information collected for AML/KYC Apply standards of knowledge and reason to know principles based on U.S. indicia For identified U.S. persons, obtain a selfcertification that includes the account holder s U.S. TIN (which may be an IRS Form W-9 or other similar agreed form) For identified U.S. persons, obtain a valid waiver and account holder s U.S. TIN (which may be an IRS Form W-9 or other similar agreed form) 5

7 IGA Model 1 Customer Due Diligence: Preexisting Individual & Entity accounts Requirements consistent with the ones in Final Regulations Aggregate the value of accounts for individuals maintained by FFI or its affiliates if on shared recordkeeping system Determine FATCA taxonomy for non- U.S. entity accounts as FFIs or NFFEs Identify each account for individuals with indications of U.S. citizenship or residency Identify the recalcitrant accounts Establish a process for tracking and retaining correspondence with the account holder Maintain scanned documents associated with each account to support the decisions and information with each account Requirements for Entity Accounts Identify known U.S. Persons and accts with balances under $50,000 Identify High Value Accts over $1mln Requirements for Individual Accounts Search for accounts that have been documented as U.S. for other tax purposes. Can elect to eliminate depository accounts with a balance or value of less than $50,000 ($250,000 for a cash value insurance or annuity contract). Determine if account balance is above $1mln and perform required due diligence for U.S. indicia and solicit necessary documentation Understand the type of entity Identify entity accts under $250,000 Determine if entities are FFIs or NFFEs Identify the place the account holders were formed or incorporated Preexisting entity accounts with account balances of $250,000 or less are exempt from review until the account balance exceeds $1,000,000 Identify accts with U.S. indicia Determine status of account and obtain necessary documentation Determine Status of entity Determine if FFI is participating or deemed compliant. Determine if NFFEs are exempt or otherwise if they have any specified U.S. owners Analyze for Exceptions Review data collected to identify any exceptions Analyze for Exceptions Determine if an entity account holder was identified as an exception to FATCA reporting 6

8 U.S. Indicia and Required Documentation U.S. Indicia Documentation Required U.S. citizenship or lawful permanent resident 1. Obtain W-9 and valid and effective waiver for non-iga countries; 2. Self-certification that includes U.S. TIN for IGA Model 1 countries U.S. birth place 1. Obtain W-9 and vailid and effective waiver or W-8BEN for non-iga countries; 2. Self-certification for IGA Model 1; and 3. Non-U.S. passport or similar documentation establishing foreign citizenship; and 4. Written explanation regarding U.S. citizenship or a copy of the individual s Certificate of Loss of Nationality of the United States or Form I-407 U.S. address (residence, correspondence, or P.O. Box) 1. Obtain W-9 and vailid and effective waiver or W-8BEN for non-iga countries; 2. Self-certification for IGA Model 1; and 3. Non-U.S. passport or similar documentation establishing foreign citizenship U.S. Telephone Number 1. Obtain W-9 and vailid and effective waiver or W-8BEN for non-iga countries; 2. Self-certification for IGA Model 1; and 3. Non-U.S. passport or similar documentation establishing foreign citizenship Instructions to transfer funds to U.S. accounts or directions regularly received from a U.S. address Only address on file is in care of or hold mail or U.S. P.O. Box (excludes foreign PO Box as U.S. indicia) Power of Attorney or signatory authority granted to person with U.S. address 1. Request W-9 and vailid and effective waiver or W-8BEN for non-iga countries; 2. Self-certification for IGA Model 1; and 3. Documentary evidence establishing non-u.s. status 1. Request W-9 and vailid and effective waiver or W-8BEN for non-iga countries; 2. Self-certification for IGA Model 1; and 3. Documentary evidence establishing non-u.s. status 1. Request W-9 and vailid and effective waiver or W-8BENfor non-iga countries ; Self-certification for IGA Model 1; and 2. Documentary evidence establishing non-u.s. status 7

9 Comparison of IGA model agreements to final regulations Issue Model 1 Model 2 Final regulations FFI agreement Not required for resident FFIs. Resident FFIs must agree to comply with the requirements of an FFI Agreement. Article 2(a). Subject to specified exceptions, all FFIs must enter into an FFI Agreement to avoid withholding. Requirement to withhold, on payments to FFIs, see Reg (a). FFI Agreement described, Reg Amendment of agreement Intended prior to December 31, Article 10. Registration with IRS Required. See, e.g., HMRC Guidance Notes, Section 2.1. Expected to be the same as Model 1. Required. Article 2(1)(a). Unknown. Required. Reg (a). Enforcement of compliance Local/IRS. Article 5. Local/IRS. Article 4. Internal compliance program; certifications; IRS. Reg (f). Significant non-compliance Must be resolved within 18 months. Article 5(2)(b). Must be resolved within 12 months. Article 4(2). Rules provided to cure event of default. Reg (g). Deemed-compliant/exempt entities Annex I(VI)(B)(4), and Annex II (by mutual Agreement). Annex I(VI)(B)(4), and Annex II (by mutual Agreement). Reg (e)(5), -5(f), -6; Reg (c). Can resident FFIs be nonparticipating FFIs? Limited to cases of unresolved significant non-compliance. Article 5(2)(b). Limited to cases of unresolved significant non-compliance. Article 4(2). Yes 8

10 Comparison of IGA model agreements to final regulations Issue Model 1 Model 2 Final regulations Due diligence requirements Annex I Annex I Reg (c). Election to follow due diligence provisions of the regulations rather than Annex I Yes. Annex I(I)(C). Yes. Binding subject to material modification rule. Annex I(I)(C). N/A Permitted to open undocumented individual accounts No, except for de minimis accounts. Annex I(III)(B). No, except for de minimis accounts. Annex I(III)(B). Yes, but subject to a limited cure period. Reg (g)(ii). Permitted to open undocumented entity accounts No; however, self-certification may not be required. Annex I(V)(B), (C). No; however, self-certification may not be required. Annex I(V)(B), (C). Yes, but subject to a limited cure period. Reg (c)(3)(ii). Required closing of recalcitrant account holders No. Article 4(2). No. Article 4(2)(a). Yes, as specified. Reg (i). Required reduction. Reg (g)(1)(ii). Required to provide financial services to specified U.S. persons Limited to small financial institutions with a local client base. Annex II. Limited to small financial institutions with a local client base. Annex II. Limited to certain deemedcompliant FFIs. Reg (f)(1)(i)(A). 9

11 Comparison of IGA model agreements to final regulations Issue Model 1 Model 2 Final regulations Resolution of conflicts of law to permit reporting Yes Yes No Reporting of information to local authority or IRS Local Authority, Article 2. IRS, Article 2. IRS, Form 8966: U.S. accounts, Reg (d)(3)(vii); recalcitrant, Reg (d)(6)(v). Information reporting requirements Specified in agreement. Article 2. Based upon regulations. Article 2. Provided in Reg (d). Reporting of U.S. accounts Automatic for reportable U.S. accounts. Article 2(1). Consent to report required from each US Account. Article 2(1). Waiver required from each U.S. account, if reporting is prevented under foreign law. Reg (i)(2). Reporting of recalcitrant accountholders Automatic for reportable U.S. accounts. Article 2(1). Treated as U.S. accountholders, total number and value to be reported, and subject to group request by U.S. Article 2(2). Reg (d)(6). U.S. reciprocity Yes* Optional No * Reciprocal agreement only. 10

12 Expanded Affiliated Group IGA Application According to Final Regulations, a limited status for an FFI and branch will cease after December 31, It is important to note that Final Regulations make an exception to FFIs located in jurisdictions subject to Model 1 or 2 Intergovernmental Agreements ( IGA ). According to both Model 1 and 2 IGA, starting January 1, 2016, FFIs in IGA jurisdictions will remain in compliance with FATCA despite being affiliated with certain nonparticipating FFIs while, in non-iga jurisdictions, a participating FFI may be deemed to be out of compliance with its FFI Agreement if it is affiliated with an FFI whose limited FFI status has just expired. Both Model 1 and 2 IGAs have a clause Special Rules Regarding Related Entities and Branches that permits FATCA Partner Financial Institution to retain their FATCA status as long as they limited FFIs and branches as separate nonparticipating financial institution and identify them as such to withholding agents. 11

13 Key Features of the FATCA Registration Portal Link: 24-hour-a-day, seven-days-a-week accessibility Allows FFI users to establish an online account, including the ability to establish an access code and challenge questions Ensure security for all data provided on behalf of FFI Provides FFIs with tools to oversee member and/or branch information 12

14 FATCA Registration Portal Interface 13

15 Registration Timeline Date Action 19 August 2013 Registration portal opening (only trial access) 1 January 2014 Submission of registration requests possible 25 April 2014 GIIN registration deadline for first 2014 list 2 June 2014 First 2014 GIIN list 1 July 2014 Begin income withholding FFI begin new account onboarding 14

16 Purpose of FATCA Registration FFI (or a foreign branch) not covered by an IGA: to enter into an FFI Agreement (on line, by checking the box) to be treated as a participating FFI, or to agree to meet the requirements to be treated as a registered deemed compliant FFI, or to confirm that it will comply with the terms applicable to a Limited FFI or a Limited Branch and to obtain a Global Intermediary Identification Number (GIIN) Reporting FFI (or a foreign branch) under Model 2 IGA: to confirm that it will comply with the terms of an FFI Agreement, as modified by the applicable Model 2 IGA to authorize one or more PoCs to obtain a GIIN Reporting FFI (or a foreign branch) under Model 1 IGA: to authorize one or more Points of Contact (PoC) to obtain a GIIN 15

17 Global Intermediary Identification Number (GIIN) The GIINis proposed to be a unique alphanumeric sequence that provides the following benefits: Provides a new way to identify a financial institution, with a distinct format that was designed so as to not be confused with existing identification/reporting numbers currently in use; Allows for easy identification of a financial institution s type, and country of residence; Associates each entity with other affiliates/branches in the same member group; Allows a residence country to use a single identification number to identify all information associated with a financial institution. 16

18 GIIN Composition GIIN is issued to FIs, other than Limited FFIs or Limited Branches, after the FATCA registration is submitted and approved. GIINs are alphanumeric, comprised of 19 characters, and are in the following format: XXXXXX.XXXXX.XX.XXX: Character Representation Position Description FATCA ID 1-6 Randomly generated number by the system 7 Separator FFI type 8-12 Single, Lead, Member, or Sponsoring Entity 13 Separator Cathegory type Two-character abbreviation identifying either the FFI cathegory or Branch of the FFI 16 Separator Country identifier Standard country code of the FFI or Branch 17

19 Information requested by the FATCA Registration Portal 1. FFI type: Lead Member Sponsoring Single 2. Legal name 3. Country of tax residence 4. FATCA classification: Participating + Model 2 Registered deemed compliant + Model 1 other 5. Mailing address 6. QI, WP or WT indicator Including EIN 7. Foreign branches: U.S. branch including TIN Foreign branches 8. Responsible officer: Name Address Phone and 9. Points of contacts Up to 5 18

20 This document contains general information only and Deloitte is not, by means of this presentation, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This presentation is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Deloitte, its affiliates, and related entities shall not be responsible for any loss sustained by any person who relies on this presentation. Certain services may not be available to attest clients under the rules and regulations of public accounting. About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting. Member of Deloitte Touche Tohmatsu Limited

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

Comparison of IGA Model Agreements to Final FATCA Regulations

Comparison of IGA Model Agreements to Final FATCA Regulations Comparison of IGA Model Agreements to Final FATCA Regulations Issue Model 1 Model 2 Final FFI agreement Not required for resident FFIs. Resident FFIs must agree to comply with the requirements of an FFI

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

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

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

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

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

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

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

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 -- 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

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

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

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

The Impact of FATCA on Mutual Funds and other Regulated, Open-ended Funds Closing the distance

The Impact of FATCA on Mutual Funds and other Regulated, Open-ended Funds Closing the distance The Impact of FATCA on Mutual Funds and other Regulated, Open-ended Funds Closing the distance Global Financial Services Industry Overview The Treasury Department and the Internal Revenue Service ( IRS

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

IIB Seminar on U.S. Taxation of International Banks FATCA FFI Agreements and Form W-8 Series Instructions

IIB Seminar on U.S. Taxation of International Banks FATCA FFI Agreements and Form W-8 Series Instructions IIB Seminar on U.S. Taxation of International Banks FATCA FFI Agreements and Form W-8 Series Instructions June 17-18, 2013 Laurie Hatten-Boyd, KPMG LLP Denise Hintzke, Deloitte Tax LLP Yaron Reich, Cleary

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

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

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

The Treasury Department and IRS Release Updates to Final FATCA Regulations as well as Coordination Regulations Closing the distance

The Treasury Department and IRS Release Updates to Final FATCA Regulations as well as Coordination Regulations Closing the distance The Treasury Department and IRS Release Updates to Final FATCA Regulations as well as Coordination Regulations Closing the distance Global Financial Services Industry Deloitte s initial analysis in response

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

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

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

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

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

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)

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

FATCA Frequently Asked Questions (FAQs) Closing the distance

FATCA Frequently Asked Questions (FAQs) Closing the distance FATCA Frequently Asked Questions (FAQs) Closing the distance Global Financial Services Industry 1. What is FATCA? FATCA stands for the Foreign Account Tax Compliance Act. It colloquially refers to provisions

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

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

David Weisner. Carolina Caballero. Today s Speakers. U.S. Tax Counsel for Asia Pacific. Citi 1 2 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

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

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

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

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

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 ( 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

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

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

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

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

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

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

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

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

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

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

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

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

FATCA: A Portfolio Manager s Guide to Navigating Uncharted Waters

FATCA: A Portfolio Manager s Guide to Navigating Uncharted Waters FATCA: A Portfolio Manager s Guide to Navigating Uncharted Waters Michael Friedman, Tax Partner, McMillan LLP Carl Irvine, Tax Principal, McMillan LLP David Sausen, Tax Partner, Kaye Scholer LLP Compliance

More information

BURT, STAPLES & MANER, LLP SUITE 850 1250 EYE STREET, NW WASHINGTON, DC 20005-3922 PHONE (202)783-1500 - FACSIMILE (202)783-1523 www.bsmlegal.

BURT, STAPLES & MANER, LLP SUITE 850 1250 EYE STREET, NW WASHINGTON, DC 20005-3922 PHONE (202)783-1500 - FACSIMILE (202)783-1523 www.bsmlegal. BURT, STAPLES & MANER, LLP SUITE 850 1250 EYE STREET, NW WASHINGTON, DC 20005-3922 PHONE (202)783-1500 - FACSIMILE (202)783-1523 www.bsmlegal.com TO: FROM: RE: Distribution Burt, Staples & Maner, LLP Final

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

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

ACFCS FATCA One Day Seminar June 21, 2013. Role and Application of Technology in FATCA

ACFCS FATCA One Day Seminar June 21, 2013. Role and Application of Technology in FATCA ACFCS FATCA One Day Seminar June 21, 2013 Role and Application of Technology in FATCA Chris Corrie VP, Global Trade and Treasury D&B Washington, DC Jerry Khan Senior Manager, Tax KPMG New York, NY Combating

More information

Facilitators Michael Miles Phil Ferrari

Facilitators Michael Miles Phil Ferrari Product Tax Seminar September 20 21, 2012 Washington, DC 1B: FATCA for Actuaries Chair Howard Stecker Facilitators Michael Miles Phil Ferrari What Actuaries Need to Know About The Impact of FATCA on Insurance

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

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

FATCA Regs Come Up Short For P&C Insurance Industry

FATCA Regs Come Up Short For P&C Insurance Industry Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com FATCA Regs Come Up Short For P&C Insurance Industry

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

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

[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

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

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

Implementation of The International Tax Compliance (United States of America) Regulations 2013. Guidance Notes

Implementation of The International Tax Compliance (United States of America) Regulations 2013. Guidance Notes Implementation of The International Tax Compliance (United States of America) Regulations 2013 Guidance Notes 14 August 2013 1 Guidance Contents 1. Background 1.1 The purpose of these Guidance notes 1.2

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

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

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

FATCA Online. Registration. User Guide. November 2015. Foreign Account Tax Compliance Act

FATCA Online. Registration. User Guide. November 2015. Foreign Account Tax Compliance Act Foreign Account Tax Compliance Act FATCA Online Registration User Guide November 2015 Publication 5118 (Rev.11-2015) Catalog Number 65265H Department of the Treasury Internal Revenue Service www.irs.gov

More information

How do the final FATCA regulations affect asset managers?

How do the final FATCA regulations affect asset managers? How do the final FATCA regulations affect asset managers? February 6, 2013 In brief The long-awaited final Foreign Account Tax Compliance Act (FATCA) regulations have arrived and, while much analysis still

More information

Foreign Account Tax Compliance Act (FATCA)

Foreign Account Tax Compliance Act (FATCA) Foreign Account Tax Compliance Act (FATCA) GUIDANCE NOTES: APPLICATION OF FATCA TO COLLECTIVE INVESTMENT VEHICLES Issued by Inland Revenue, New Zealand 30 July 2014 Version 1.0 Please direct all comments

More information

FATCA Q & A REPORTING AND WITHHOLDING

FATCA Q & A REPORTING AND WITHHOLDING FATCA Q & A REPORTING AND WITHHOLDING Issue 1 Luxembourg, June 26th, 2015 Important This Q&A document was prepared by ALFI's implementation working groups for the U.S. Foreign Account Tax Compliance Act

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

STATUTORY INSTRUMENTS. S.I. No. 292 of 2014 FINANCIAL ACCOUNTS REPORTING (UNITED STATES OF AMERICA) REGULATIONS 2014

STATUTORY INSTRUMENTS. S.I. No. 292 of 2014 FINANCIAL ACCOUNTS REPORTING (UNITED STATES OF AMERICA) REGULATIONS 2014 STATUTORY INSTRUMENTS. S.I. No. 292 of 2014 FINANCIAL ACCOUNTS REPORTING (UNITED STATES OF AMERICA) REGULATIONS 2014 2 [292] S.I. No. 292 of 2014 FINANCIAL ACCOUNTS REPORTING (UNITED STATES OF AMERICA)

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

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

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

Foreign Account Tax Compliance Act Frequently Asked Questions

Foreign Account Tax Compliance Act Frequently Asked Questions FATCA - The Basics (an overview) 1. What is FATCA? FATCA, which became effective July 1, 2014, stands for the Foreign Account Tax Compliance Act. It was created by the U.S. Internal Revenue Service (IRS)

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

Below is a summary of the main issues discussed during our April 28 meeting, and our recommendations for resolving them.

Below is a summary of the main issues discussed during our April 28 meeting, and our recommendations for resolving them. Donna J. Fisher Senior Vice President Tax, Accounting & Financial Management (202) 663-5318 DFisher@aba.com September 11, 2015 Theodore D. Setzer International Business Compliance - Foreign Payments Program

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

Private Equity Alert

Private Equity Alert March 1, 2013 Private Equity Alert Final FATCA Regulations Released Impact on Private Investment Funds On January 17, 2013, the US Treasury and the IRS released final regulations under the Foreign Account

More information

The International Tax Authority. Version 2.0

The International Tax Authority. Version 2.0 The International Tax Authority GUIDANCE NOTES ON THE INTERNATIONAL TAX COMPLIANCE REQUIREMENTS OF THE LEGISLATION IMPLEMENTING THE INTERGOVERNMENTAL AGREEMENTS BETWEEN THE BRITISH VIRGIN ISLANDS AND THE

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

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

Now, therefore, the Parties have agreed as follows: ARTICLE 1. Definitions

Now, therefore, the Parties have agreed as follows: ARTICLE 1. Definitions AGREEMENT BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND TO IMPROVE INTERNATIONAL TAX COMPLIANCE AND TO IMPLEMENT

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

www.pwc.com/us/fatca Ready, set, FATCA: How the new rules will affect insurers, and why early action is the best policy July 2011

www.pwc.com/us/fatca Ready, set, FATCA: How the new rules will affect insurers, and why early action is the best policy July 2011 www.pwc.com/us/fatca Ready, set, FATCA: July 2011 How the new rules will affect insurers, and why early action is the best policy Introduction In March of 2010, the Foreign Account Tax Compliance Act (FATCA)

More information

What s News in Tax Analysis That Matters from Washington National Tax

What s News in Tax Analysis That Matters from Washington National Tax What s News in Tax Analysis That Matters from Washington National Tax FATCA and Foreign Leasing Companies The Foreign Account Tax Compliance Act ( FATCA ) imposes withholding and reporting requirements

More information

United States of America No. 1 (2012) Agreement

United States of America No. 1 (2012) Agreement United States of America No. 1 (2012) Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to Improve International

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

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

FATCA AND NEW ZEALAND LAW FIRMS

FATCA AND NEW ZEALAND LAW FIRMS This Practice Briefing does not constitute legal advice INTRODUCTION The FATCA agreement between New Zealand and United States is directed at reducing tax evasion by US taxpayers. New Zealand law firms

More information

Automatic Exchange of Information

Automatic Exchange of Information Automatic Exchange of Information The Common Reporting Standard How financial institutions can adapt to new global standards kpmg.com TAX KPMG INTERNATIONAL Contents Summary A coordinated effort against

More information

Business Information Form

Business Information Form Head Office One Westmount Road North P.O. Box 1603 Stn. Waterloo, Waterloo Ontario N2J 4C7 TF 1.800.668.4095 T 519.886.5210 Fax 1.519.883.7404 Business Information Form Applicant/Owner (first, last) Application/Policy

More information

Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers?

Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers? Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers? February 20, 2012 How do the proposed FATCA regulations impact Insurers On February 8th, the highly anticipated proposed regulations

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