Tax & Accounting Blog

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Further Extension of FATCA Timeline Requested by Four Financial Industry Associations

In a joint letter to the Department of Treasury and Internal Revenue Service, four financial industry associations have requested a further postponement of FATCA milestone dates in order to help ensure a smooth transition to the FATCA regime. IRS Notice 2013-43 postponed certain implementation dates for FATCA (the Foreign Account Tax Compliance Act) from January … Read More

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IRS Postpones Information Reporting by Domestic Entities for Specified Foreign Financial Assets

On January 23, 2013, the IRS issued Notice 2013-10. The Notice postpones the date that domestic entities, including trusts, will be required to report their interests in specified foreign financial assets on Form 8938. Background Code § 6038D was enacted by section 511 of the Hiring Incentives to Restore Employment Act (the … Read More

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Why Nature of Income Paid to Foreign Vendors Matters Part 7 – Tax Treaty Exemptions from Withholding

A common withholding exemption is a claim under an applicable provision of an income tax treaty with the country of tax residence of the income’s beneficial owner. Such a claim must be made by the vendor on a valid Form W- 8BEN, or a Form 8233 in the case of treaty claims by individuals on … Read More

Why Nature of Income Paid to Foreign Vendors Matters Part 6 – Exemptions from Withholding

Why Nature of Income Paid to Foreign Vendors Matters Part 6 – Exemptions from Withholding

Whether an exemption from withholding under either income tax rules or an applicable income tax treaty applies depends on the character of the U.S.-source income being paid (as defined by U.S. tax rules). For example, a foreign vendor with income that is effectively connected to the conduct of a U.S. trade or business (called “ECI”) … Read More