Home      Login

Abstract: 

In January 2016, the IRS issued Notice 2016-08, which, most importantly, delayed the timing for participating foreign financial institutions and compliant foreign financial institutions located in Model 2 IGA jurisdictions to certify as to their FATCA compliance. The authors address the importance of these FATCA certifications, why these certifications were modified, and the Notice’s impact on the timing of the certification. In addition, they describe and explain several other clarifications to the FATCA regulations made in the Notice.

Keywords: FATCA; foreign financial institutions; Notice 2016-08; compliance certifications; gross proceeds; electronic W-8s

Affiliations:  1: Mayer Brown LLP; 2: Mayer Brown LLP.