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Category Archives: FATCA

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IRS Will Extend Some FATCA Transition Rules

Posted in FATCA, General, International

In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on gross proceeds and foreign passthrough payments will begin; (2) the use of limited branches and limited foreign financial institutions (limited FFIs);… Continue Reading

More FATCA Transition Relief and Clarification

Posted in FATCA, International

New Notice 2014-33 sets forth calendar years 2014 and 2015 as a transition period for IRS FACTA implementation enforcement for withholding agents, foreign financial institutions and certain other withholding responsibilities.  However, an entity that has not made good faith efforts to comply with the new requirements will not be given any relief from IRS enforcement… Continue Reading


Posted in FATCA, General, International, Procedure

On April 18 and again on May 1, the IRS issued newly updated Frequently-Asked-Questions for FATCA compliance following their recent comprehensive regulations on the topic.  The FATCA rules create a series of documentation rules and a potential 30% withholding tax on payments to non-U.S. financial entities.  The Q&A guidance includes answers to common questions relating… Continue Reading

New FATCA Regulations Incorporate Taxpayer Comments and Clean Up Existing Rules

Posted in FATCA, International, Procedure

Today the IRS announced two new sets of regulations on the FATCA rules.  In general, FATCA creates 30% withholding on certain distributions to certain Foreign Financial Institutions (FFIs) unless those FFIs comply with onerous rules to disclose certain investor information to the U.S. government. The new regulations are T.D. 9657 and T.D. 9658. The new… Continue Reading

New IRS On-Line FATCA Registration System

Posted in Compliance, FATCA, International

The latest Foreign Account Tax Compliance Act (FATCA) guidance is the on-line registration system.  The IRS also published a 4-page overview and 75 pages of instructions for the new registration system.  Prior Tax Law Roundup articles describe FATCA and the related deadlines. FATCA Online Registration System Overview  The IRS describes the system as follows: Under… Continue Reading

IRS Issues Final FATCA Foreign Account Regulations

Posted in Compliance, FATCA, International

The IRS published extensive 544-page final regulations on Foreign Account Tax Compliance Act (FATCA), finalizing the 2012 proposed regulations.  The final regulations address detailed taxpayer comments on the need to reduce FATCA administrative burdens and address technical implementation.  The regulations are effective January 28, 2013.  For an overview of the final regulations see the IRS… Continue Reading

New Proposed FATCA Regulations Try to Ease Compliance Burden

Posted in FATCA, General, International, Procedure

New proposed regulations under the Foreign Account Tax Compliance Act (FATCA) implement FATCA’s obligations in stages to minimize burdens on foreign financial institutions (FFIs), and to allow time for resolving local law limitations to which some FFIs may be subject.  The IRS press release notes that the 388-page proposed regulations will: Permit FFIs in many… Continue Reading