Stephen Fiamma and Stefka Kavaldjieva explain why the recently released intergovernmental agreement on FATCA (the IGA) between the US and the UK provides welcome prospective relief from many burdensome aspects of FATCA reporting and withholding.
The Foreign Account Tax Compliance Act (FATCA) imposes a 30% US withholding tax on certain payments (generally US source payments gross proceeds from the sale of property producing US source interest and dividends and certain not-yet-defined ‘foreign payments’) made to foreign financial institutions (FFIs) that do not report to the US Internal Revenue Service (the IRS) information about financial accounts held by US persons (US accounts) (non-participating FFIs). While the implementation of FATCA presents numerous challenges among the most difficult are bank secrecy data protection and similar laws that prohibit FFIs from disclosing account information to the IRS. Without some other means of reporting the information sought by...
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Stephen Fiamma and Stefka Kavaldjieva explain why the recently released intergovernmental agreement on FATCA (the IGA) between the US and the UK provides welcome prospective relief from many burdensome aspects of FATCA reporting and withholding.
The Foreign Account Tax Compliance Act (FATCA) imposes a 30% US withholding tax on certain payments (generally US source payments gross proceeds from the sale of property producing US source interest and dividends and certain not-yet-defined ‘foreign payments’) made to foreign financial institutions (FFIs) that do not report to the US Internal Revenue Service (the IRS) information about financial accounts held by US persons (US accounts) (non-participating FFIs). While the implementation of FATCA presents numerous challenges among the most difficult are bank secrecy data protection and similar laws that prohibit FFIs from disclosing account information to the IRS. Without some other means of reporting the information sought by...
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