Arun Srivastava
Foreign financial institutions could face significant consequences if they fail to enter into the above described agreement with the IRS, or to otherwise comply with theFATCAregulations - the non-compliant financial institutions shall be subject to a 30%withholdingtax on any “withholdablepayment” mad...
FATCA imposes a withholding tax of 30 percent nonrefundable tax on income from the United States paid to certain types of FFIs and NFFEs. As the world of FATCA withholdings breaks down into two major categories, FFIs and NFFEs, there is a set of hard and fast rules that are applicable...
Expand the scope of "grandfathered obligations" that are not subject to FATCA withholding to include any payment made under an obligation outstanding on January 1, 2013 (and any gross proceeds from the disposition of such an obligation); Delay full implemen...
Withholding, Depositing and Refunding Tax 5. Information Reporting 6. Control and Oversight 7. Penalties 8. Issues for NQIs PART II: FATCA 9. Moral Outrage and Righteous Indignation 10. Principles of FATCA 11. Simplifying FATCA 12. Identification and Documentation 13. Reporting 14. FATCA ...
taxpayers or face 30 percent withholding on certain payments they receive. FATCA also imposes new withholding and reporting obligations on U.S. financial institutions as well as nonfinancial U.S. companies with respect to payments they make to foreign entities. The U.S. Treasury Department and ...
fatcaalfiwithholdingreportingirsluxembourg FATCA Q & A REPORTING AND WITHHOLDING Issue1Luxembourg,June26th,2015-June 26th, 2015 ‐ ALFI Q & A Reporting and Withholding, Issue 1 Page 2/33 ImportantThisQ&AdocumentwaspreparedbyALFI'simplementationworkinggroupsfortheU.S.ForeignAccountTaxComplianceAct(FATCA)...
IRS Issues Proposed Regulations Eliminating the FATCA Withholding Tax on Certain Sales Proceeds Alerts IRS Issues Proposed Regulations Eliminating the FATCA Withholding Tax on Certain Sales Proceeds
On May 2, 2014, the IRS released Notice 2014-33 providing for a transition period for purposes of IRS FATCA enforcement and administration, as well as notice of IRS and Treasury intent to amend the Chapter 4 regulations to allow a withholding agent to treat c...
The authors are at pains to point out that some FATCA penalties are being applied erroneously even at the level of US withholding agents because of a failure to interpret the regulations correctly and more commonly to mix up the issues of IRC Chapter 3 with IRC Chapter 4 The authors note ...