Every foreign entity must take steps immediately to determine whether FATCA will apply to it and, if so, whether FATCA registration will be required by April 25, 2014....more
On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more
On August 19, 2013, the IRS began to accept applications for registration under FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, by requiring foreign financial institutions (“FFIs”),...more
On July 12, 2013, the IRS issued new guidance regarding FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers. In particular, the IRS (1) revised certain elements of the timeline for FATCA...more
Offshore Master with U.S. and Offshore Feeders -
This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more
This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more
Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more
U.S. Funds with Only U.S. Investors -
FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more