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More Countries Joining the Transparency Trend

On October 29, more than 50 countries signed on to implement OECD standard for automatic exchange of information starting in 2017 or 2018.  The Secretary-General of the OECD, Angel Gurria, announced at the end of the Global Forum on Transparency and Exchange of Information for Tax Purposes that of the 123 Global Forum members, close to 90 agreed to implement the international...

Switzerland Moving Towards International Standards

Switzerland recently announced intentions for draft legislation to provide authority for amending existing double taxation avoidance agreements that would bring them in line with the OECD’s standard for exchange of information provisions.  The proposal would authorize the use of a unilateral extension to execute the amendments.  The amendments would apply the OECD standard to any...

FATCA Enforcement Relaxed Until 2016

Like the Rolling Stones, those facing FATCA obligations are saying “Time is On My Side.”  Withholding agents, foreign financial institutions (FFIs), and other entities making “good faith efforts to comply with the new regulations, forms, and other requirements of [the Foreign Account Tax Compliance Act]” will only face light enforcement for two years, the IRS said in...

Time for a Little Spring Cleaning: IRS Releases Final Version of Form W‑8BEN-E for FATCA Compliance

On March 28, the IRS released the final version of Form W-8BEN-E for use by entities to meet the reporting and withholding requirements under the Foreign Account Tax Compliance Act (FATCA).  With FATCA’s initial compliance deadline of July 1, 2014, quickly approaching, the release of the final Form W-8BEN-E is a welcome event for those striving to meet the requirements of the new...

Republican Party Platform: Ditch FATCA

Apparently, the reporting requirements of foreign financial institutions have now become partisan red meat. On Friday, the Republican National Committee made repeal of the Foreign Account Tax Compliance Act (FATCA) part of its party platform. A resolution passed by voice vote at the RNC’s annual winter meeting in Washington, D.C., establishing a party position on the anti-tax-evasion...

France and U.S. Sign FATCA IGA; Agreements Furthering U.S. Tax Transparency Initiatives Now at Double-Digits

A significant part of the global tax reform discussion has centered on global tax transparency and increased information sharing and the intergovernmental agreement (“IGA”) signed between the U.S. and France to implement the Foreign Account Tax Compliance Act (“FATCA”) furthers the tax transparency agenda.   The IGA with France marks the tenth IGA signed to date. Generally,...

Tides of Change: Cayman Islands Announces Completion of FATCA Accord with the United States

On August 13, the Cayman Islands announced the conclusion of negotiations with the United States on an intergovernmental agreement (IGA) to implement the U.S. Foreign Account Tax Compliance Act (FATCA) and a new tax information exchange agreement (TIEA).  According to media reports, the countries will adopt a Model 1B nonreciprocal FATCA IGA, which will require the Cayman Islands...

FATCA as a Global Model

When the Foreign Account Tax Compliance Act (FATCA) was enacted in 2010, there was some question as to how it would be received internationally and whether tax compliance and information reporting initiatives would gain traction globally.  Although the operative provisions of FATCA are not yet in effect, the law has had significant international influence in shaping global tax...

Tides of Change: CARICOM Announces Progress on FATCA Compliance and Other Financial Matters

The Caribbean region came one step closer to conformity with the U.S. Foreign Account Tax Compliance Act (FATCA) at the Fifteenth Meeting of the Council for Finance and Planning (the Council) of the Caribbean Community (CARICOM) held on August 7.  During that meeting, the Council agreed upon a coordinated approach to negotiations with the U.S. concerning compliance with FATCA that will...

U.S. Pushes Global Information Exchange at G8 Summit

The U.S. hopes to build international consensus around combating tax evasion and corporate profit shifting at this week’s G8 meeting in Northern Ireland.  Specifically, the U.S. is pushing a single global standard of information exchange, based on the Foreign Account Tax Compliance Act (better known as FATCA).  In comments to reporters, President Obama’s special assistant for...

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