A report published by the China Post in Taiwan on Sunday, hinted that another six-month delay may be likely in implementing the Foreign Account Tax Compliance Act (“FATCA”). If the report is correct, this would be the third delay in rolling out what has been described by many as the most over-reaching and egregious US legislation to come down the pike. In October 2012 and again in July of 2013, the US announced six-month delays in implementing FATCA due to the practical difficulties in setting up the measures required to have foreign financial institutions around the world reporting about their United States customers.

If the latest report is true, it would be the third time that the US has delayed implementing FATCA. Perhaps, third time, the charm? Read More

The Internal Revenue Service has just issued Revenue Procedure 2014-10 which provides guidance to foreign financial institutions (FFIs) entering into an FFI agreement with the IRS for FATCA (Foreign Account Tax Compliance Act) purposes. The final version of the FFI agreement is set forth in meticulous detail in the Revenue Procedure. The final FFI agreement contained in the Revenue Procedure contains a number of changes to provisions of the draft FFI agreement set out in an earlier IRS Notice (Notice 2013-69 2013-46 I.R.B. 503), on October 29, 2013.

Who Should Sign the FFI Agreement?

FFIs signing the FFI agreement will be treated as “participating FFIs”. Generally, these are Read More

In his contribution to the House of Assembly, on August 12, 2013, Minister of Financial Services Ryan Pinder said that the Bahamas Government has agreed that the country will achieve compliance under the United States Foreign Accounts Tax Compliance Act (FATCA) by negotiating and entering into a Model 1 Intergovernmental Agreement (IGA) with the United States Department of the Treasury.

Minister Pinder said: “The Government of The Bahamas has also agreed to the establishment of an inter-Ministerial committee on FATCA under the leadership of the Ministry of Financial Services be established with the following mandate: to prepare an implementation strategy for FATCA, inclusive of the draft FATCA Agreement; to prepare and Read More

The United States Department of the Treasury announced today that the United States has signed an intergovernmental agreement (IGA) with France to implement the Foreign Account Tax Compliance Act (FATCA). Enacted in 2010, FATCA aims to curtail offshore tax evasion by facilitating the exchange of tax information.

With today’s agreement, 10 FATCA IGAs have been signed to date.

“France has been an enthusiastic supporter of our effort to promote global tax transparency and critical to drafting a model of FATCA implementation,” said Deputy Assistant Secretary for International Tax Affairs Robert B. Stack. “This agreement demonstrates the growing global momentum behind FATCA and strong support from the world’s most important Read More