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The Unintended Consequences of the HIRE Act: Impact on Offshore Financial Transactions  


Author:  Marnin Michaels.; Michael Parets.; Tom O’Donnell.; Alyssa Varley.


Source: Volume 23, Number 06, July/August 2010 , pp.29-40(12)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

Although primarily intended to stimulate new hiring by American businesses, the HIRE Act of 2010 also includes provisions originally introduced in a bill to increase foreign account tax compliance. These provisions hold some unwelcome surprises—and potential compliance headaches—for financial institutions and their customers. What is more, the authors contend, they could actually serve to discourage tax compliance and to discourage investment in U.S. capital markets.

Keywords: H.R. 3933; S. 1934; FATCA; foreign financial institutions; non-financial foreign entities; foreign transfers; foreign trusts; offshore tax evasion

Affiliations:  1: Baker and McKenzie; 2: Baker and McKenzie; 3: Baker and McKenzie; 4: Baker and McKenzie.

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