FATCA Client Letters

FATCA Transition Relief: Notice 2011-53
(July 15, 2011)
The IRS has responded to industry and foreign government concerns regarding the January 1, 2013, effective date of the chapter 4 provisions of FATCA ...
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Immediate Action Required for Participating FFIs with Respect to Responsible Officer Certifications
(May 6, 2011)
Although FATCA is not effective until January 1, 2013, foreign financial institutions (FFIs) that intend to enter into FFI Agreements with the IRS (“participating FFIs”) ...
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IRS Releases Notice 2011-34 – Second FATCA Notice
(April 11, 2011)
On April 8, 2011, Treasury and the IRS issued a second FATCA notice, Notice 2011-34 (the "Notice") supplementing Notice 2010-60 and providing new guidance in several ...
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IRS Comments on FATCA Notice 2010-60
(September 23, 2010)
Several senior IRS executives addressed the Tax Executives Institute in New York City on September 22, 2010, as part of a panel chaired by John Staples, and commented on FATCA Notice 2010-60 (the “Notice”). ...
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First Round of FATCA Guidance Published by IRS
(August 30, 2010)
On Friday, August 27, the IRS published Notice 2010-60 (“Notice”), the first round of guidance under the Foreign Account Tax Compliance Act (“FATCA”) provisions ...
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Notice 2010-46: New Securities Lending/Repo Rules: Notice 2010-46 Replaces Notice 97-66
(May 24, 2010)
What is the purpose of Notice 2010-46? The Notice implements section 871(l)(6) of the Foreign Account Tax Compliance (“FATCA”) provisions of the HIRE ...
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U.S. Withholding and Information Reporting on Dividend Equivalents Begins September 14, 2010
(April 16, 2010)
ALERT: Clients should be aware that new section 871(l) enacted as part of FATCA requires withholding on dividend equivalents beginning on or after September ...
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FATCA is Now Law
(March 18, 2010)
Today, the President signed into law a major revamp of the U.S. withholding tax system that imposes a new 30% withholding tax on certain U.S. source payments ...
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Do You Have a 2010 Strategy to Deal with Cost Basis Reporting and FATCA?
(February 8, 2010)
Proposed regulations mandating cost basis reporting (“CBR”)and potential passage of the Foreign Account Tax Compliance Act (“FATCA”) constitute the biggest ...
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Likely Consequences to Financial Institutions from the IRS Voluntary Disclosure Program for U.S. Holders of Undisclosed Offshore Accounts
(January 28, 2010)
Over 14,000 U.S. taxpayers trying to escape criminal prosecution have voluntarily disclosed their offshore accounts to the IRS in the last few months. More such...
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U.S. Withholding Tax Legislation Introduced on October 27, 2009
(October 30, 2009)
Key Congressional tax writers introduced the “Foreign Account Tax Compliance Act of 2009” (“Act”) on October 27, 2009, with the U.S. Treasury expressing its support...
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Drastic Changes to Qualified Intermediary (“QI”) Program Proposed by Obama
(May 7, 2009)
The Obama Administration has proposed to Congress sweeping changes in the QI program and the way nonqualified intermediaries (“NQIs”) are treated. If these proposals are adopted ...
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