FATCA: IRS unveils second round of significant guidance
Jesse Eggert, US Department of the Treasury, joins our panel to discuss Notice 2011-34
On 7 April, the Internal Revenue Service issued Notice 2011-34, a supplement to Notice 2010-60 issued in August 2010. This represents the second significant piece of guidance on the implementation of the expansive information reporting and withholding regime contained in the Foreign Account Tax Compliance Act (FATCA) provisions enacted a year ago. The Notice addresses several high priority issues raised by taxpayers and commentators and includes some requests from the government for further comments from industry on matters they are considering. Among the areas addressed in the Notice are further refinements to the rules for identification of pre-existing accounts, the first indication of the government’s approach to the pass thru payment concept, proposed new options for treatment as a “deemed compliant FFI,” more specifics around the reporting required with respect to US accounts and details regarding the application of the FATCA provisions to affiliated groups.
This new information reporting regime applies to a broad spectrum of financial institutions, including many that may never before have been subject to requirements such as these, and carries the potential for application of a 30% withholding tax in cases where there is not full compliance with the new requirements.
Do you know where your company stands and what's required by 2013? There is much to be done between now and the January 2013 effective date for these FATCA provisions.
Please join us for a 90-minute webcast on Wednesday, 20 April at 11:00 a.m. EDT as Jesse Eggert, Attorney Advisor, US Department of the Treasury, Office of International Tax Counsel joins our panel of Ernst & Young LLP professionals to discuss the various elements of this initial guidance and what your company can do to prepare to meet these FATCA obligations.
Jesse Eggert, Attorney Advisor, US Department of the Treasury, Office of International Tax Counsel
Barbara Angus, International Tax Services, Ernst & Young LLP
Debbie Pflieger, Information Reporting and Withholding Services, Ernst & Young LLP
Julia Tonkovich, International Tax Services, Ernst & Young LLP
Terry Cardew, Financial Services Office, Ernst & Young LLP