IRS Guidance on FFIs and FATCA

In preparation for the implementation of the reporting andwithholding requirements for the Foreign Account Tax Compliance Act (FATCA), the IRS has issued Notice 2013-69, itslatest guidance applicable to foreign financial institutions (FFIs) enteringinto an FFI agreement with the IRS or to FFIs treated as reporting financialinstitutions under a Model 2 intergovernmental agreement.

Under FATCA, U.S. withholding agents must withhold tax oncertain payments to FFIs that don’t agree to report certain information to theIRS concerning their U.S. accounts as well as certain payments to certainnonfinancial foreign entities that don’t provide information on theirsubstantial U.S. owners to withholding agents.

See Guidance Issued for FFIs with FATCAAgreement, AICPA, Oct. 29, 2013. 

Special thanks toJim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringingthis article to my attention.