Growth
FATCA UpdateIRS and Treasury issue proposed and temporary regulations under FATCA as well as ‘conforming regulations’ under chapters 3 and 61
On 20 February 2014, the IRS and Treasury released proposed and temporary regulations (TD 9657 and TD 9658) providing further guidance under the Foreign Account Tax Compliance Act (FATCA) and “conforming” the requirements in chapters 3 and 61 of the Internal Revenue Code (i.e., the Section 1441 rules applicable to withholding and reporting on payments made to nonresident aliens and the Form 1099 reporting and backup withholding requirements imposed on payments to US persons) with the requirements of FATCA, which is also known as “chapter 4.”
Our alert below details the implications of these releases.
Growth
FATCA UpdateIRS and Treasury issue proposed and temporary regulations under FATCA as well as ‘conforming regulations’ under chapters 3 and 61