FATCA/CRS

US posts two new FATCA FAQs

The US has posted new frequently asked questions (FAQs) to its FATCA website regarding registration for nonreporting financial institutions in Model 1 IGA jurisdictions and self-certifications on similarly agreed forms . . .

Americas

US IRS gives countries with “in substance” FATCA IGAs more time to sign IGAs, adds more countries to the “in substance” list

The US IRS on December 1 released an advance copy of guidance that provides that countries that have reached FATCA intergovernmental agreements (IGAs) “in substance” that do not sign an IGA by December 31 will continue to be treated as if an IGA was in effect as long as the country displays a “firm resolve” to sign an IGA as soon as possible. The new guidance . . .

Americas

IRS updates FATCA Withholding Foreign Partnership and Withholding Foreign Trust agreements

The U.S. IRS, on August 8, released Rev.Proc. 2014-47, which updates the Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) agreements for foreign partnerships and trusts that seek to enter into a WP or WT withholding agreement with the IRS under ­reg. section 1.1441-5(c)(2)(ii) and (e)(5)(iv). The new agreements replace agreements found in Rev. Proc. 2003-64, 2003-2 C.B. 306. Rev. Proc. 2014-47

Americas

IRS releases updated qualified intermediary agreement

The IRS has released Rev. Proc. 2014-39, which includes an updated qualified intermediary (QI) agreement. The revenue procedure supersedes the QI agreement originally released as Rev. Proc. 2000-12. Rev Proc. 2014-39 also outlines the application procedures and the requirements for qualified intermediary status under Chapters 3, 4, and 61 and Section 3406. Rev. Proc. 2014-39