Scott R. MacLeod is a partner and James S.
"Jay" Crenshaw and Amy R. Rigdon are Associates in our
Orlando office .
HIGHLIGHTS:
- Foreign financial institutions must perform due diligence to
identify their U.S.-owned accounts and report them to the IRS, as
well as act as a withholding agent for payments to other foreign
entities. Those "FFIs" that do not comply with these
Foreign Account Tax Compliance Act (FATCA) requirements could face
a 30% withholding tax.
- Some FFIs will need to register with the IRS and sign a
Participating FFI Agreement. The deadline has been extended from
April 25, 2014 to May 5, 2014.
A. Background and Status: The Foreign Account
Tax Compliance Act ("FATCA") requires foreign financial
institutions ("FFIs"), including most non-U.S. investment
funds, to engage in specified due diligence procedures to identify
their U.S.-owned accounts, report their U.S.-owned accounts to the
Internal Revenue Service ("IRS"), and act as a
withholding
