Analysis of FATCA Proposed Regulations
On February 8, 2012, the Treasury Department and the Internal Revenue Service (the "IRS") issued proposed regulations for the next major phase of implementing the Foreign Account Tax Compliance Act ("FATCA"). The regulations lay out a step-by-step process for U.S. account identification, information reporting, and withholding requirements for foreign financial institutions ("FFIs"), certain non-financial foreign entities ("NFFEs") and U.S. withholding agents.
Douglas S. Stransky and Martha F. Coultrap wrote an article entitled "Analysis of FATCA Proposed Regulations," which appeared in the March 31, 2012 edition of Practical International Tax Strategies. This article highlights the significant modifications and additions to guidance previously provided by the Treasury and the IRS.