Tax & Accounting Blog

Understanding W-8BENs – A Foreign Perspective

W-8BENs have been around for just over 10 years and it has taken the select few that currently use them years of cumbersome administration – and some painful audit procedures – to truly understand how they need to be completed correctly. Now that we’ve finally grasped them, we are soon to be faced with not just one … Read More

Revised IRS Guidance: FATCA

Revised IRS Guidance: FATCA

FATCA Tax Withholding Phase-In Applies to Payments to Foreign Entities, in addition to Foreign Financial Institutions IRS Notice 2011-53, originally issued on July 14, was revised and reissued on July 25 to clarify that FATCA withholding will be phased in for payments to foreign entities, following the same extended schedule announced in the original Notice … Read More

New FATCA Notice Released – Notice 2011-53

New FATCA Notice Released – Notice 2011-53

On July 17, 2011,  the IRS released a new notice, 2011-53, which provides a ‘workable timeline for FFIs and U.S. Withholding Agents to implement the various requirements of FATCA’. Specifically: • An FFI must enter an agreement with the IRS by June 30, 2013, to ensure that it will be identified as a participating FFI … Read More

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Revised Form 8809 (Application for Extension of Time to File Information Returns)

With the release of a new version of Form 8809 in May 2011,  the field to enter a TCC was removed since it is apparently not needed with extension filings for information returns. Noted with a caution in the on-form 8809 instructions is the statement, “if you are requesting an extension for more than one filer, you must … Read More

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Understanding the Difference between Documented and Undocumented

It is important to keep in mind that, as a general rule, all US source payments made to non-US residents are subject to 30% withholding. To apply a reduced (or zero) rate of withholding, the non-US person must provide valid documentation. If your securities account is with a Withholding Agent (a Qualified Intermediary, Non-Qualified Intermediary … Read More