United States: How do the latest information reporting requirements impact your nonfinancial multinational company? (Part 2)

June 2014
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United States: How do the latest information reporting requirements impact your nonfinancial multinational company? (Part 2)

At a glance

The requirements of the Foreign Account Tax Compliance Act (FATCA) and other recently revised US information reporting regulations are either effective immediately or are set to apply beginning on July 1. These rules not only impact the financial services sector, but are expected to affect many entities outside of the traditional financial services sector with operations both in and outside of the United States.

This is the latest in our series of Tax Insights describing some of the significant items in the regulations impacting nonfinancial MNCs. The topics addressed in this insight include:

  • Documentation needed to classify payees - Rules have been updated relating to the expiration of Forms W-8, validity of facsimile or emailed forms, and coordination of documentation standards under FATCA with Chapters 3 and 61 and Section 3406 of the Code.
  • Presumption rules used when payees do not provide sufficient documentation - The presumption rules under existing Chapters 3 and 61 of the Code have been modified to reflect the requirements of FATCA.

An earlier Tax Insight examined entities classified as FFIs, classification of nonfinancial foreign entities (NFFEs), the responsibilities of sponsored entities, the alignment of withholding requirements, and revised reporting obligations. Please also see another earlier Tax Insight which highlighted many of the updates provided in these final and temporary regulations affecting all industries.