FATCA in 2015—Now the Fun Really Begins
Author: Daniel Mulcahy.; Mark Howe.
Source: Volume 32, Number 02, Winter 2015 , pp.11-22(12)
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Abstract:
While the Foreign Account Tax Compliance Act (FATCA) technically became operational in mid-2014, many obligations under the law first take effect in 2015. For example, the first reports are due in 2015, and enhanced due diligence on new entity accounts begins in 2015. Hedge fund managers, investment advisors, foreign trustees, and withholding agents must continue to understand and focus on their FATCA responsibilities to ensure that necessary compliance steps are taken going forward.Keywords: FATCA; Foreign Account Tax Compliance Act; FFIs; foreign financial institutions; IGAs; Intergovernmental Agreements; withholding; due diligence; Form W-8BEN-E; Announcement 2014-38
Affiliations:
1: Cadwalader, Wickersham & Taft LLP; 2: Cadwalader, Wickersham & Taft LLP.