Final and temporary Chapters 3 and 4 regulations contain several changes relating to identification and documentation of account holders and payees
Changes to identification and documentation of account holders and payees
This publication provides readers with the latest news and insights regarding domestic and international information reporting and withholding, including in-depth perspectives on new IRS protocols and procedures as well as the techniques, tools, and technology to keep your company at the forefront of compliance.
Changes to identification and documentation of account holders and payees
IRS announces LB&I ‘campaigns’
Final and temporary Chapter 3 regulations modernize account documentation and US withholding tax information sharing
A new playing field: The convergence of tax regulations with other global risk
Final, temporary, and proposed regulations under Sections 871(m) and 1441 dealing with dividend equivalent payments
Final qualified intermediary agreement includes qualified derivatives dealer provisions
New IRS portal for qualified intermediary agreement applications
Regulatory amendments for compliance with and enforcement of the Common Reporting Standard in the Cayman Islands
IRS releases final qualified intermediary agreement
IRS releases revised FFI agreement and other FATCA related guidance
Treasury and IRS issue extensive regulatory guidance package related to US information reporting and withholding rules
Considering FATCA implications when US source insurance premiums are paid on offshore obligations
FBAR filing date extended for some filers due to lack of final regulations
IRS notice provides relief under Section 871(m) regulations and qualified derivatives dealer regime
Increased penalties for failure to timely file correct information returns and failure to furnish correct payee statements.
Required reporting of specified foreign financial assets with 2016 federal income tax returns
Proposed regulations revise rules for reporting qualified tuition and related expenses on Form 1098-T.
IRS proposes updated qualified intermediary agreement.
Proposed qualified intermediary agreement includes qualified derivatives dealer provisions.
The Cayman Islands recently extended to August 10, 2016 the UK CDOT and US FATCA notification and reporting due dates.
Immediate action required by asset managers to address US tax withholding and reporting on dividend equivalent payments
United States: FinCEN proposes favorable, adverse changes to FBAR filing requirements
Request to extend time to file FATCA Report with IRS due March 31
The IRS begins denying refunds of withholding tax credits claimed on Form 1040NR as substantiated on Forms 1042-S.
The Internal Revenue Service recently released a draft of Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities), and draft Instructions for Form W-8BEN-E. Non-US (foreign) entities use Form W-8BEN-E to make several certifications relevant to US withholding tax and information reporting
PATH Act includes important information reporting and withholding provisions
IRS expands non-recognition treatment of identity protection services relating to data breach.
FBAR filing date further extended for certain officers and employees with signature authority.
Updated Cayman Island AEOI Portal User Guide provides clarification on notification for sponsored FIs
The Cayman Department for International Tax Cooperation recently launched its Automatic Exchange of Information Portal.
The IRS released final forms and instructions used to comply with the new ACA information reporting requirements
IRS issues final regulations with respect to foreign financial assets that do not significantly alter previous guidance.
FinCEN on December 10, 2014 issued Notice 2014-1 to further extend the filing date of FBAR
US Department of the Treasury provides FATCA relief to jurisdictions with IGAs treated as in effect.
Recently released instructions to the 2014 Form 1042-S clarify FATCA reporting requirements for US premiums.
There are areas where it was not appropriate for UK CDOT to exactly mirror US FATCA due to differences in context.
Global Information Reporting: OECD publishes long anticipated Commentary on Common Reporting Standard.
The IRS recently published final regulations allowing filers of certain information returns to use truncated TINs.
The IRS recently released the instructions for Form W-8BEN-E for complying with FATCA.
FATCA not only impacts the financial services sector, but many entities outside of the traditional financial services sector with operations in and outside of the US.
The US Treasury and IRS announced in Notice 2014-33 that 2014 and 2015 will be a transition period for IRS enforcement and administration with respect to FATCA.
FATCA and other recently issued US information reporting regulations are effective immediately or apply beginning July 1, affecting many nonfinancial services entities.
IRS expands when a jurisdiction will be treated as having an IGA in effect and extends to May 5, 2014 the time by which FFIs must register with the IRS.
Treasury and the IRS recently released the last substantial package of regulations necessary to implement FATCA, with varying impacts to insurance companies.
Treasury and the IRS recently released FATCA amendments and coordinating regulations.
The US Treasury and the IRS released on February 20 final and temporary regulations for FATCA and coordinating regulations for Chapters 3, 4 and 61.
The OECD recently released the Common Reporting Standard to establish a new global standard for automatic exchange of financial account information.
This Tax Insight serves as a high-level primer of information reporting and withholding requirements for 2014 and beyond.
Soon to be released 'Common Reporting Standard' promises new FATCA-type obligations around the world.
On December 26, 2013, the IRS released the final FFI agreement (to implement FATCA) which contains a number of changes and clarifications to the draft FFI Agreement.
The IRS issued Notice 2013-69 addressing FFI agreements and related issues under FATCA and accompanying regulations.
On October 11, 2013 the Chancellor announced that the UK and Isle of Man had signed an automatic tax information exchange agreement based on FATCA (the US Foreign Account Tax Compliance Act). This Newsbrief provides an update and background information on the agreement.
This Newsbrief describes key changes contained in the technical correction and provides observations.
IRS announced in Notice 2013-56 that it would be providing penalty relief for incorrect name and taxpayer identification number combinations reported.
On August 29, 2013, the IRS released a new Form W-9, Request for Taxpayer Identification Number and Certification and its instructions. The Form W-9 is one of several forms being revised to conform to the provisions of FATCA. This Newsbrief provides an overview and key observations of the new Form W-9.
On August 14, 2013, HM Treasury and HMRC issued updated Guidance Notes (“UK Guidance”) in respect of the Implementation of The International Tax Compliance (United States of America) Regulations 2013 (“UK Regulations”) laid before the UK House of Commons earlier this month.This version of the guidance supersedes any versions previously published. This Newsbrief identifies key changes and certain additions from the draft UK Guidance released in May 2013.
The Internal Revenue Service (IRS) announced the opening of the Foreign Account Tax Compliance Act (FATCA) registration system on August 19, 2013. This Global IRW Newsbrief provides background information, important deadlines, key observations, and next steps.
Key observations from HM Treasury and HMRC’s release of the International Tax Compliance (United States of America) Regulations 2013 to improve international tax compliance and implement FATCA.
These procedural changes are intended to make it easier for FBAR filers to use the e-filing system.
Understanding the effects of the European Commission’s proposed amendments to the automatic exchange of information (“AEOI”) between EU Member States.
The IRS has recently released drafts of certain FATCA-related forms.
This Newsbrief identifies key changes from the draft UK Regulations released in December and highlights relevant aspects of the associated Guidance Notes.
This Newsbrief provides an overview of the key elements of the German-U.S. IGA and how it compares to the Model 1 IGA.
Important guidance for entities that are classified as FFIs under FATCA and considering applying for qualified intermediary, withholding foreign partnership, or withholding foreign trust status.
Form 8957, when issued in final form, may be used by foreign financial institutions (FFIs) to register for FATCA purposes.
In this Newsbrief, we take a closer look at the potential impact of FATCA on the global captive insurance market.
The US Department of the Treasury and the Internal Revenue Service provided welcome relief on a number of key issues for the asset management industry.
Related to the insurance industry, these final FATCA regulations contain a number of significant differences from the proposed regulations.
500 pages of guidance in the form of final regulations to implement the provisions of the Foreign Account Tax Compliance Act (FATCA)
Final regulations were issued along with a press release on January 17, 2013
A new whitepaper from PwCs cross isciplined Global Information Reporting practice.
Proposed regs to implement and expand the application of a voluntary IRS pilot program that permits filers to truncate taxpayer identification numbers (TINs).
The previous deadline of June 30, 2013 has been extended to June 30, 2014 for eligible officers and employees to file their 2010, 2011 and 2012 FBARs.
Treasury published the second model intergovernmental agreement (IGA) (Model 2) for implementing the broad-ranging provisions of the Foreign Account Tax Compliance Act.
Eleven of the European Union (EU) member states are moving rapidly towards agreement on the introduction of a financial transaction tax
The guidance describes the conditions necessary for a withholding agent to rely on a Form W-8 that is received via fax or e-mail.
The department of the Treasury is working to implement the information reporting and withholding tax provisions of FATCA.
IRS issued a notice extending effective dates for certain provisions of FATCA and modifying a number of key concepts
11 Member States support a common 'EU-wide' financial transactions tax (FTT) in their countries via an 'enhanced cooperation' legislative procedure
HMRC subsequently released Implementing the UK-US FATCA Agreement Consultation Document (Consultation Document) which addresses the implementation of the US-UK IGA.
The US Department of the Treasury and UK's HM Treasury announced the signing of the first intergovernmental agreement under FATCA
New draft Forms W-8EXP and W-8ECI may resolve conflicts over the 'capacity' of a signer.
ISDA released a new protocol which may provide payors with an opportunity to allocate the cost of FATCA Withholding to their counterparties, rather than treat FATCA Withholding as an 'Indemnifiable Tax' for which a payor has responsibility.
Today, the Internal Revenue Service (IRS) released a preliminary draft Form W-8IMY, Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding.
Treasury released a model intergovernmental agreement for implementing the broad-ranging provisions of the Foreign Account Tax Compliance Act (FATCA).
A new procedure allows certain low compliance risk US taxpayers living abroad who have failed to timely file US tax returns and Reports of Foreign Bank Accounts (FBARs) to get current by filing income tax returns going back three years and FBARs going back six years.
Section 6050W of the Internal Revenue Code and the regulations thereunder require merchant acquiring entities and third-party settlement organizations to report payments made in settlement of payment card (i.e., credit, debit, etc.) and third-party network transactions.
This year Forms TD F 90.22-1, Report of Foreign Bank and Financial Accounts (FBAR), reporting a financial interest in or signature or other authority over foreign financial accounts held during 2011 must be received by Friday June 29, 2012.
On 21 June 2012, Japan and Switzerland each released a joint statement with the U.S. government regarding their intention to explore and negotiate an intergovernmental agreement (“IGA”) to facilitate the implementation of the FATCA.
Treasury and IRS held a public hearing in Washington, DC on May 15, 2012 to permit those affected by the proposed FATCA regulations to express their concerns and to provide Treasury and IRS an opportunity to question the commentators.
Under IRC section 6050P, certain lenders are required to report to the IRS and the debtor information about a full or partial discharge of indebtedness of $600 or more during thecalendar year.
On Nov 25, 2011, the IRS issued proposed regulations with a proposed effective date of January 1, 2013 titled 'Basis Reporting by Securities Brokers and Basis Determination for Debt Instruments and Options' which describe the basis reporting requirements related to debt instruments and options.
On April 17, 2012, the IRS released final regulations that expand U.S. tax information reporting requirements to include bank deposit interest paid to nonresident alien (NRA) individuals resident in certain countries.
Many multinational corporations (MNCs) whose primary business activities are outside of the traditional financial services industry mistakenly believe FATCA will not impact them. However, FATCA may impact all MNCs in at least one of the following three ways.
Notice 2010-60, released in Aug 2010, provided the first directional thinking on how the provisions of FATCA would operate.
The Financial Crimes Enforcement Network (FinCEN) released Notice 2012-1, to further extend the due date to file their Form TD F 90.22-1, Report of Foreign Bank and Financial Accounts (FBAR), from June 30, 2012 until June 30, 2013.
The Foreign Account Tax Compliance Act (FATCA) is expected to have a pervasive impact on many financial institutions organized in the U.S. and globally.
Officers and employees who are U.S. citizens or residents may have to file a Form TD F 90.22-1, Report of Foreign Bank and Financial Accounts (FBAR), by June 30, 2012 to report afinancial interest in, or signature or other authority over, foreign financial accounts.
Notice 2012-11 provides that posting Form 8937, Report of Organizational Actions Affecting Basis of Securities, on the issuer's primary public website by January 17, 2012 will satisfy the filing obligations with respect to organizational actions occurring in 2011.
On January 5, 2012, the IRS issued the instructions and final version of Form 8937, Report of Organizational Actions Affecting Basis of Securities.