The US Foreign Account Tax Compliance Act (FATCA) creates a new tax information reporting and withholding regime for payments made to certain foreign financial institutions and other ‘foreign’ persons. The definition of ‘foreign financial institution’ is very broad and includes funds. Failure to report could result in a 30% withholding tax being deducted from US […]

The US introduced a number of measures in the Foreign Account Tax Compliance Act, commonly known as ‘FATCA’, to tackle the use of offshore accounts by US taxpayers to evade US tax. The US has entered into tax agreements with various countries including the UK in order to implement it. FATCA, which comes into effect […]

Over the last year there has been unparalled press coverage on the global exchange of tax information. In many cases this is a response by governments in the developed world to the global financial crisis and the subsequent fiscal. Governments need to increase tax revenues – targeting those individuals who are under declaring their taxes […]

Her Majesty’s Revenue and Customs (HMRC) has issued guidance on the implementation of the International Tax Compliance (United States of America) Regulations 2013, which come into force on 1 September 2013. The guidance is designed to assist businesses, their advisers and HMRC staff and applies, in particular to, UK financial institutions, UK entities that will […]

On Thursday, January 17, 2013, the U.S. Treasury Department and the Internal Revenue Service (IRS) released the long-awaited final regulations for the Foreign Account Tax Compliance Act (FATCA). FATCA, codified as Chapter 4 of the Internal Revenue Code, represents the Treasury Department’s efforts to prevent U.S. taxpayers who hold financial assets in non-U.S. financial institutions […]

Six-Month Extension of FATCA Deadlines and Other Guidance Regarding Implementation On July 12, 2013 in Notice 2013-43 (the “Notice”),  the Internal Revenue Service (the “IRS”) announced a six-month extension to key FATCA start dates including FATCA withholding and “grandfathering obligations,” which have both been extended to July 1, 2014.  Corresponding adjustments to various other timeframes, […]

HMRC has published draft regulations for compliance with the US Foreign Account Tax Compliance Act (FATCA).  The draft regulations are published alongside guidance notes, a tax information and impact note, and an explanatory webpage. The regulations are expected to come into force in mid-August and will apply to financial accounts (as defined in the legislation) held at […]

The US has given non-US financial institutions around the world another six months to prepare to comply fully with FATCA, pushing the deadline back to 1 July, 2014. Friday’s statement by the Internal Revenue Service announcing the extension represents the second postponement of the final compliance date, and was widely seen as a measure of […]