New FATCA Agreements Released, 2014 Agreements Expire

William Byrnes

The IRS released Revenue Procedure 2017-21, which contains the updated withholding foreign partnership (WP) agreement and withholding foreign trust (WT) agreement.

The revenue procedure provides information on submitting an application or request for renewal of a WP or WT agreement.

These WP and WT agreements allow a foreign partnership or foreign trust to assume the withholding and reporting obligations under chapters 3 (provisions relating to withholding of tax on nonresident aliens and foreign corporations) and 4 (provisions under the Foreign Account Tax Compliance Act, or FATCA) for certain payments of US source income (such as interest, dividends, and royalties) made to its direct partners, beneficiaries, or owners, and in some cases, persons holding interests in the partnership or trust through one or more foreign intermediaries or flow-through entities (indirect partners).

William H. Byrnes has achieved authoritative prominence with more than 20 books, treatise chapters and book supplements, 1,000 media articles, and the monthly subscriber Tax Facts Intelligence. Titles include: Lexis® Guide to FATCA Compliance, Foreign Tax and Trade Briefs, Practical Guide to U.S. Transfer Pricing, and Money Laundering, Asset Forfeiture; Recovery, and Compliance (a Global Guide). He is a principal author of the Tax Facts series. He was a Senior Manager, then Associate Director of international tax for Coopers and Lybrand, and practiced in Southern Africa, Western Europe, South East Asia, the Indian sub-continent, and the Caribbean. He has been commissioned by a number of governments on tax policy. Obtained the title of tenured law professor in 2005 at St. Thomas in Miami, and in 2008 the level of Associate Dean at Thomas Jefferson. William Byrnes pioneered online legal education in 1995, thereafter creating the first online LL.M. offered by an ABA accredited law school (International Taxation and Financial Services graduate program).

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