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Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more
As 2016 comes to a close, U.S. FATCA is almost fully phased-in, U.K. FATCA is being phased-out and the Common Reporting Standard (“CRS”) is nearing the first anniversary of its effective date. What began as a concept in 2010...more
As noted in the Foley Adviser dated April 14, 2016, there are several upcoming FATCA-related deadlines, two of which are right around the corner: ..June 30, 2016: Foreign Financial Institution Due Diligence for...more
2016 Compliance Update - For the past few years, FATCA has dominated the international tax compliance landscape. As that regime continues to be phased-in, a new regime – the Common Reporting Standard (“CRS”) – will begin...more
The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more
On September 18, 2015, the IRS announced its intention to amend the U.S. FATCA regulations to extend the effectiveness of certain transitional rules, including...more
On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more
Pursuant to Notice 2014-33 (the Notice), the IRS announced that it will treat calendar years 2014 and 2015 as a transition period for the administration and enforcement of the due diligence, reporting, and withholding...more
The rapid evolution of the Foreign Account Tax Compliance Act (“FATCA”) from a U.S. driven effort to crack down on U.S. offshore tax evaders into an information reporting mechanism being considered for adoption throughout the...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more
On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more
On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more
On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more
On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account...more
On July 26, 2012, the Treasury Department released two versions of a model intergovernmental agreement (model IGA) for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA). One...more
Proposed Regulations under the Foreign Account Tax Compliance Act Issued February 8, 2012 On February 8, 2012, the U.S. Treasury Department and the Internal Revenue Service ("IRS") released widely anticipated proposed...more
In This Presentation: FATCA: Foreign Account Tax Compliance Act - History - Nuts and Bolts - Highlights of Proposed Regulations - Intergovernmental Agreement - Next Steps - Q&A Please see full...more
On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more
On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). In drafting the Proposed...more
On February 8, 2012, the U.S. Treasury and the Internal Revenue Service (the IRS) issued proposed regulations on the implementation of the withholding and due diligence provisions of the Foreign Account Tax Compliance Act...more