Updated Draft of Form W-8BEN-E for Entities

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The IRS has released another draft of the Form W-8BEN-E for entities. As expected, the form has changed drastically since the draft published last year and has increased from six to eight pages. Two significant changes include the addition of sections designed specifically for disregarded entities and branches receiving payments and the expected change to…



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Luxembourg to enter into Model 1

The Luxembourg Ministry of Finance announced, during an interview held on May 21, 2013, that Luxembourg will enter into a Model 1 IGA. The FATCA negotiations with the U.S. started in April 2013, but the type of model IGA remained uncertain until yesterday. This decision was expected since the announcement made by the Ministry of…

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New Draft Form W-9

The IRS has released a new draft version of the Form W-9. The new form adds two new fields; one to indicate the type of entity that is exempt from back-up withholding and the other to indicate the type of entity that is exempt from FATCA withholding. The instructions include an updated list of exempt…

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Updated Draft of Form W-8BEN for Individuals

The IRS has released another draft of the Form W-8BEN for individuals. In addition to the changes included in the original draft released last year, the updated draft adds (i) a date of birth field and (ii) language in the “Certification” section requiring the signatory to agree to submit a new form within thirty days…

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Likely model documents pertaining to the Singapore IGA

The following are the likely model documents pertaining to the Singapore IGA: Nonreciprocal Model 1B Agreement, No TIEA or DTC (Updated 5-9-2013)* Annex I to Model 1 Agreement (Updated 5-9-2013) Annex II to Model 1 Agreement (Updated 5-9-2013) Note: Singapore does not have pre-existing exchange of information provisions with the U.S. The U.S. provides only…

Inland Revenue welcomes sharing of tax haven information

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10 May 2013 Inland Revenue has welcomed the decision by the tax authorities in the United Kingdom, United States and Australia to share data on those involved with international tax havens. Group Manager, Compliance Planning and Development, Raju Budhia, said that some New Zealand residents and shell companies have participated in such offshore arrangements. “We…

Spain signs Model 1 IGA

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Spain signed a Model 1 IGA on May 14. The agreement had been initialed in November, 2012, and was awaiting authorization by the Spanish government. The finance minister was authorized to sign the agreement in April.

Singapore announces it will enter into a Model 1 IGA

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Among several measures to significantly strengthen its framework for international cooperation to combat cross-border tax offences, the Singapore Government announced that it intends to conclude a Model I IGA on FATCA with the US Department of the Treasury. See the press release here.

U.S. Treasury updates Model IGAs and Annexes

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The U.S. Treasury has posted updated model IGAs. Each model now includes a version for jurisdictions not having a preexisting TIEA or DTC with the U.S. Previously, separate model IGAs were not expected in order to accommodate jurisdictions not having exchange of information provisions with the U.S. Further analysis will follow See footnote 1 to Annex II:…

IRS, Australia and United Kingdom Engaged in Cooperative Effort to Combat Offshore Tax Evasion

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IR-2013-48, May 9, 2013 [Text of IRS news release IR-2013-48:] WASHINGTON — The tax administrations from the United States, Australia and the United Kingdom announced today a plan to share tax information involving a multitude of trusts and companies holding assets on behalf of residents in jurisdictions throughout the world. The three nations have each acquired a…

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