News & Analysis as of

Internal Revenue Service Foreign Account Tax Compliance Act Foreign Investment

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

International Business and Offshore Investment and Banking Create Genuine IRS Risk

Allen Barron, Inc. on

International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more

Allen Barron, Inc.

Is it Time to Rethink Your Offshore PFIC Investment(s)?

Allen Barron, Inc. on

Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer?...more

Dorsey & Whitney LLP

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

Dorsey & Whitney LLP on

An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

Cadwalader, Wickersham & Taft LLP

Tax Update: IRS Trims Back FATCA

On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. ...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

Troutman Pepper

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

Troutman Pepper on

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

Morrison & Foerster LLP

After Months of Anticipation, Final FATCA Regulations Released

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act (“FATCA”). ...more

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