Tax & Accounting Blog


Revised FATCA Foreign Financial Institution Agreement

IRS Revenue Procedure 2014-13, which will be published in the January 13, 2014, Internal Revenue Bulletin, contains the revised text of the FFI Agreement between a participating FFI (foreign financial institution) and the Internal Revenue Service under section 1471(b) of the Internal Revenue Code and § 1.1471-4 of the Income Tax Regulations. It details the … Read More


18 Countries Have Signed Intergovernmental Agreements with the U.S. for FATCA Implementation

The United States Department of the Treasury recently released the text of six new intergovernmental agreements (IGAs) for the implementation of FATCA (the Foreign Account Tax Compliance Act).  Four of these are reciprocal Model 1 IGAs between the United States and Malta, the Netherlands, Guernsey, and the Isle of Man.  The fifth is a reciprocal … Read More


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


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