Wills, Trusts & Estates Prof Blog

Editor: Gerry W. Beyer
Texas Tech Univ. School of Law

Friday, November 8, 2013

IRS Guidance on FFIs and FATCA


In preparation for the implementation of the reporting and withholding requirements for the Foreign Account Tax Compliance Act (FATCA), the IRS has issued Notice 2013-69, its latest guidance applicable to foreign financial institutions (FFIs) entering into an FFI agreement with the IRS or to FFIs treated as reporting financial institutions under a Model 2 intergovernmental agreement.

Under FATCA, U.S. withholding agents must withhold tax on certain payments to FFIs that don’t agree to report certain information to the IRS concerning their U.S. accounts as well as certain payments to certain nonfinancial foreign entities that don’t provide information on their substantial U.S. owners to withholding agents.

See Guidance Issued for FFIs with FATCA Agreement, AICPA, Oct. 29, 2013. 

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.


Current Affairs, Income Tax | Permalink

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