International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Tuesday, March 14, 2017

New FATCA foreign partnership (WP) agreement and withholding foreign trust (WT) agreements released, 2014 agreements expire

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

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

William Byrnes' best-selling Guide to FATCA & CRS Compliance published by LexisNexis – NEW 2017 Edition free download here

Over 1,800 pages of analysis of the FATCA and CRS compliance challenges,  79 chapters by FATCA and CRS contributing experts from over 30 countries.  Besides in-depth, practical analysis, the 2017 edition includes examples, charts, time lines, links to source documents, and compliance analysis pursuant to the IGA and local regulations for many U.S. trading partners and financial centers.   The Lexis Guide to FATCA Compliance, designed from interviews with over 100 financial institutions and professional firms, is a primary reference source for financial institutions and service providers, advisors and government departments.  The chapters include by example in-depth analysis of designing a FATCA internal policy, designing an equivalent form to the W-8, reporting accounts, reporting payments, operational specificity of the mechanisms of information capture, management and exchange by firms and between countries, insights as to the application of FATCA, CRS, and the IGAs within BRIC, SEA and European country chapters.  This fifth edition provides the financial enterprise’s FATCA compliance officer the tools for developing and maintaining a best practices compliance strategy.  No filler of forms and regs – it’s all beef !

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