Pillsbury Winthrop Shaw Pittman

FATCA starts to become visible for multinational companies — part one

By James P Klein

Enacted in 2010, the US Foreign Account Tax Compliance Act (FATCA) mandates US citizens and green-card holders to report their non-US financial accounts plus related investment earnings to the Internal Revenue Service (IRS). The reporting structure consists of two related strands, individual-level reporting and programme-level reporting. The individual-level reporting strand requires US persons to report their non-US accounts as part of their federal income tax filing while the programme-level reporting requires foreign financial institutions that operate financial accounts for US persons to report on these annually to the IRS.

Part one of this two-part series provides an overview of the programme-level reporting issues that multinational corporations must manage with regard to their non-US long-term benefits plans…

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