January 2017
The US Department of the Treasury and the Internal Revenue Service recently issued a series of extensive regulatory guidance (combined over 950 pages) related to the US information reporting and withholding rules which impact both US and non-US persons. While a number of provisions of the US Internal Revenue Code and related regulations are affected, most of the impact is to the following areas:
Observation: While a significant portion of the guidance codified and further explained changes provided in prior Notices and public comments, a large portion of the guidance is new and will need to be assessed for its impact on existing processes and systems.