Impact of FATCA on multinational corporations that are not in the financial services industry

| June 2012

Overview

Nonfinancial MNCs that were in compliance with existing tax reporting and withholding requirements are discovering they have many new responsibilities and requirements as a result of the modifications to the FATCA regulations.

These regulations not only impact payment flows; they also impact payee documentation requirements and the associated presumption rules when documentation is not provided. Moreover, nonfinancial MNCs are discovering that foreign financial institutions exist in their group despite FATCA providing many exceptions and special carve outs that limit which entities are considered to be financial institutions.

These regulations not only impact payment flows; they also impact payee documentation requirements and the associated presumption rules when documentation is not provided. Moreover, nonfinancial MNCs are discovering that foreign financial institutions exist in their group despite FATCA providing many exceptions and special carve outs that limit which entities are considered to be financial institutions.

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