October 24, 2014

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October 24, 2014

October 23, 2014

October 22, 2014

Foreign Account Tax Compliance Act "FATCA" Regulations Are Finalized

On January 18, the Treasury Department issued final regulations under the Foreign Account Tax Compliance Act (FATCA). The final regulations incorporate the FATCA guidance that the Internal Revenue Service (IRS) has issued since proposed FATCA regulations were issued last February, as well as certain comments received regarding the proposed FATCA regulations.

The final regulations also provide clarification and details with respect to:

  1. the method, timing and general content that will need to be included in an agreement that a foreign financial institution (FFI) will need to enter into with the IRS to avoid FATCA withholding;
     
  2. phased-in timelines for due diligence, reporting and withholding;
     
  3. rules concerning intergovernmental agreements; and
     
  4. procedures for compliance and registration by sponsors of commonly managed FFIs.

We intend to issue a client advisory discussing the FATCA final regulations.

Read more.

©2014 Katten Muchin Rosenman LLP

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About this Author

Robert Loewy, Tax Attorney, Katten Muchin Law firm
Special Counsel

Robert Loewy concentrates his practice in tax planning and litigation.

Robert advises domestic and foreign clients on a broad range of US and international tax issues. His practice is both transactional and advisory, focusing on the taxation of financial instruments and products, hedge funds and private clients. He also has extensive experience in advising clients as to the tax consequences of domestic and cross-border mergers, acquisitions and restructurings.

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