IRS Releases Instructions for the Requestor of Forms W-8


On July 18, 2014, the IRS released the Instructions for the Requester of Forms W-8BEN, W-8BEN-E, W-8ECI, W-8EXP, and W-8IMY (“Requester Instructions”). The Requester Instructions supplement the instructions for the noted Forms and can be used to help withholding agents and Foreign Financial Institutions (“FFIs”) in validating the Forms for both chapter 3 and 4 […]


New and Updated FATCA FAQs Posted on July 10, 2014

The following new and updated FAQs were posted on July 10, 2014, by the IRS. IGA Registration Does an FFI in a Model 1 IGA jurisdiction need to register before July 1, 2014, if the FFI is part of an EAG? No.  The chapter 4 regulations generally provide that, in order for withholding not to apply, […]


HMRC will update U.S. Guidance Notes concerning Trusts as Investment Entities

HM Revenue & Customs (HMRC) will update the US guidance notes in August to clarify when: a trust will qualify as a financial institution as a result of the professional management of the trust’s assets by another financial institution the assets under management are considered to be the assets of the trust In the interim, […]


Can a U.S. Citizen Open a High Value Foreign Deposit Account and Not be Reported to the IRS?

The answer: Yes, depending on the bank. A foreign bank which meets the Local Foreign Financial Institution (FFI) requirements in either Annex II of an IGA or in the U.S. Treasury Regulations is not required to report a U.S. citizen if that individual is resident in the country in which the bank is licensed and regulated […]


IRS Releases Update to Registration User Guide

The addendum updates the naming conventions of the country lookup table.

Jamaica Model 1 IGA Available


The Model 1 IGA signed by Jamaica with the U.S. on May 2 is available here.

Israel signs Model 1 IGA


On June 30, Israel signed a Model 1 IGA with the U.S. The agreement is available here.

Corrections to the Temporary Regulations Modifying the Final FATCA Regulations


The IRS has released corrections to the final and temporary regulations (TD 9657), which were published in the Federal Register on Thursday, March 6, 2014 (79 FR 12812). The regulations relate to information reporting by foreign financial institutions (FFIs) with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities.

Guernsey Announces U.S. and U.K. Effective Dates

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States of Guernsey Income Tax MEDIA RELEASE – 12 June 2014 FOR IMMEDIATE RELEASE Notification of effective dates for the Intergovernmental Agreements with the UK and US relating to FATCA The Director of Income Tax has today provided clarity regarding certain effective dates in Guernsey’s Intergovernmental Agreements (IGAs) with the United Kingdom (UK) and the […]

Do you really want to use the Alternative Procedures in Annex I?


The most recent versions of the IGA Models both include Alternative Procedures in Annex I. These become effective if the FATCA Partner jurisdiction notifies the U.S. in writing that it lacks the legal authority to require Reporting FATCA Partner Financial Institutions either: to require Account Holders of New Individual Accounts to provide the required self-certification, […]

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