IRS releases long-awaited draft FFI agreement and previews updates to FATCA regulations
By Michael J Legamaro, Witold Jurewicz and Michael Greenberg
The Internal Revenue Service (IRS) has released Notice 2013-69, including a draft FFI agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA).
The draft FFI agreement outlines the obligations of foreign financial institutions (FFIs) that will register with the IRS to become participating FFIs (PFFIs) under FATCA.
FFIs and their branches located in countries that have entered into a Model 2 intergovernmental agreement (IGA) with the US (Model 2 FFIs) will also be required to agree to comply with the terms of an FFI agreement, as modified by the terms of the applicable Model 2 IGA. PFFIs and Model 2 FFIs will avoid the new 30 per cent FATCA withholding tax on US source payments made to FFIs, beginning 1 July 2014…
If you are registered and logged in to the site, click on the link below to read the rest of the DLA Piper briefing. If not, please register or sign in with your details below.
News from DLA Piper
News from The Lawyer
Briefings from DLA Piper
Corporate liability: the Italian Supreme Court extends the scope of application of Legislative Decree No. 231/2001
The Italian Supreme Court has reconsidered the possibility of applying Legislative Decree No. 231/2001 to the so-called target offences of a criminal organisation.
In autumn 2011, Thailand suffered severe floods. Among the properties damaged were shops and distribution centres owed by a subsidiary of Tesco.
Analysis from The Lawyer
Shearman & Sterling is making its presence felt in the City, squaring up to magic circle firms and looking to muscle in on key relationships. Private equity house Bridgepoint is one outfit that has had its head turned by the US firm.
A new breed of lawyer is smoothing the path for companies entering emerging or unstable jurisdictions