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On Dec. 6, 2016, the IRS and Treasury issued temporary (T.D. 9800) and proposed (REG-129128-14) regulations under Section 901(m).

Every foreign entity must take steps to determine whether FATCA will apply to it and whether FATCA registration will be required by April 25, 2014.

The United States and Brazil have signed a "Model 1" intergovernmental agreement ("IGA") with respect to the US Foreign Account Tax Compliance Act.

On 11 July 2023, the Luxembourg Parliament voted with an absolute positive majority on the bill of law 8183 which was proposed by the Luxembourg Government on 24 March 2023.

On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure to report their offshore accounts.

On July 1, 2014, FATCA will go into effect.

On March 26, 2009, the Internal Revenue Service ("IRS") made public a program allowing U.S. persons with foreign financial accounts to greatly reduce their exposure to significant civil penalties and, in many cases, to eliminate the prospects of criminal prosecution.

The IRC restricts the ability of offshore funds domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S. persons.

The US Department of the Treasury recently announced that the United States has signed a "Model 1" intergovernmental agreement with respect to the US Foreign Account Tax Compliance Act ("FATCA") with the Cayman Islands.

Any discussion of the regulatory landscape across the globe is complicated by the dominance of U.S. regulators in the statistics.

We last updated our readers in February 2014 on issues related to the disclosure and automatic exchange of financial information on an international basis.

U.S. taxpayers with unreported foreign accounts or assets are in an increasingly precarious position.

FATCA refers to the US Foreign Account Tax Compliance Act (contained in Sections 1471 through 1474 of the US Internal Revenue Code).