Tax Law

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FATCA Implementation: Take Two
Posted on 16 May 2011 by Ivan Mitev

... [A] FATCA implementation report by Navigant prepared in the aftermath of Notice 2010-60 and sent to me by my colleague Rich Kando. This first report could be found here . Subsequent to... Notice 2011-34, Navigant... prepared an updated implementation... Read More

Tags: FATCA implementation , Notice 2011-34 , Notice 2010-60

More FATCA Reporting Requirements Guidance for FFIs
Posted on 10 May 2011 by Neil Aragones

In April, the IRS issued Notice 2011-34, modifying and supplementing initial guidance provided by Notice 2010-60 on the future reporting, documentation, and withholding requirements for foreign financial institutions (FFIs) that have U.S. accounts. Notice... Read More

Tags: HIRE Act , IRC Section 1471 , Hiring Incentives to Restore Employment Act , private banking department , preexisting individual account , Notice 2011-34 , Notice 2010-60 , private banking relationship

Notice 2011-34: The Second Round of FATCA Guidance Is Released
Posted on 19 Apr 2011 by Ivan Mitev

... [Notice 2011-34 FATCA] guidance comes in the form of another voluminous notice... which, in addition... Notice 2010-60, comes to a... possible 100-150 page proposed regulation, counting the preamble. It seems paradoxical... when everybody is talking... Read More

Tags: Private Equity , Venture Capital and Hedge Fund Taxation , Notice 2011-34 , Notice 2010-60

Treasury Official: Payments Under Fixed-Term Revolvers Likely to Qualify for FATCA Exemption
Posted on 26 Jan 2011 by Matthew Kaden

On Friday, January 21, 2011, a Treasury Department official [Itai Grinberg] gave his views on the treatment an important issue under FATCA that affects the PE and VC industries... [Grinberg] stated that he believed that payment obligations under revolving... Read More

Tags: IRC Section 1471 , Notice 2010-60 , Itai Grinberg

  • Blog Post: Treasury Official: Payments Under Fixed-Term Revolvers Likely to Qualify for FATCA Exemption

    Matthew Kaden
    On Friday, January 21, 2011, a Treasury Department official [Itai Grinberg] gave his views on the treatment an important issue under FATCA that affects the PE and VC industries... [Grinberg] stated that he believed that payment obligations under revolving credit agreements outstanding as of March 18...
    on 26 Jan 2011

  • Blog Post: Notice 2011-34: The Second Round of FATCA Guidance Is Released

    Ivan Mitev
    ... [Notice 2011-34 FATCA] guidance comes in the form of another voluminous notice... which, in addition... Notice 2010-60, comes to a... possible 100-150 page proposed regulation, counting the preamble. It seems paradoxical... when everybody is talking about simplifying the Tax Code. I'd venture...
    on 19 Apr 2011

  • Blog Post: More FATCA Reporting Requirements Guidance for FFIs

    Neil Aragones
    In April, the IRS issued Notice 2011-34, modifying and supplementing initial guidance provided by Notice 2010-60 on the future reporting, documentation, and withholding requirements for foreign financial institutions (FFIs) that have U.S. accounts. Notice 2011-34, 2011 IRB LEXIS 234 ; Notice 2010-60...
    on 10 May 2011

  • Blog Post: FATCA Implementation: Take Two

    Ivan Mitev
    ... [A] FATCA implementation report by Navigant prepared in the aftermath of Notice 2010-60 and sent to me by my colleague Rich Kando. This first report could be found here . Subsequent to... Notice 2011-34, Navigant... prepared an updated implementation report [below]... I think that Navigant has done...
    on 16 May 2011