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Abstract: 

The Foreign Account Tax Compliance Act (FATCA) generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on withholdable payments. This article describes the types of payments and entities subject to the withholding tax regime under FATCA and sets out the general framework within which FATCA operates; it then details how to comply with FATCA documentation requirements in the context of an investment fund designed to send funds to offshore accounts.

Keywords: Foreign Account Tax Compliance Act; foreign financial institutions; non-financial foreign entities; withholding tax; withholdable payments; U.S. payors; effectively connected income

Affiliations:  1: Shumaker.