On January 17, 2013, the Department of Treasury and the Internal Revenue Service (IRS) announced the release of the final FATCA regulations (Regulations). The Regulations become effective on January 28, 2013, and diverge significantly from the current temporary regulations. While there are numerous changes in the Regulations, we highlight just some of the significant changes:…
DetailsThe Foreign Account Tax Compliance Act (FATCA) and its subsequent regulations have created a dizzying array of implementation deadlines for taxpayers, financial institutions, and withholding agents. The accompanying chart organizes the key dates related to FATCA implementation. Please note that because of the complexity of FATCA it was not practical to include all implementation dates…
DetailsAfter publishing final rules regarding people reporting their signature authority over foreign financial accounts, the Financial Crimes Enforcement Network (FinCen) received questions and comments about reporting for certain types of accounts. In response FinCen delayed the reporting requirement for individuals with signature authority over these types of accounts until June 30, 2012. The most problematic…
DetailsOn December 3, 2012, the US and Switzerland initialed a bilateral agreement to implement Foreign Account Tax Compliance Act (FATCA) (the agreement must still be approved by the Swiss Parliament). Previously, on November 20, 2012, Spain announced that it had agreed to a bilateral agreement implementing FATCA and on November 19, 2012, the IRS announced…
DetailsOn November 19, 2012, the IRS announced that the US and Mexico have signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA). This announcement comes just a couple days after the November 14, 2012 announcement that the US and Denmark signed a similar bilateral agreement to implement FATCA. With the addition…
DetailsThe Internal Revenue Service (IRS) announced on November 19, 2012, that the US and Denmark have reached an agreement for information sharing to improve tax compliance and implementation of the Foreign Account Tax Compliance Act (FATCA). This development fits with the Treasury’s earlier announcement that it is negotiating similar agreements with more than 50 countries. The…
DetailsThese publications do not constitute legal advice. Further information regarding this notice. As of 2009, the Internal Revenue Service (IRS) estimated that more than 7 million US citizens live outside of the US. However, according to the IRS’s 2006 data only 669,701, a fraction of the citizen living abroad, filed tax returns claiming exclusion for…
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