MoFo Tax Talk: Volume 6, Issue 4

EDITOR'S NOTE

Before we completely close the door on 2013 and ring in 2014, this issue of Tax Talk brings you some of last quarter's more noteworthy tax highlights and developments.

As always, it brings us great joy to share the latest Foreign Account Tax Compliance Act ("FATCA") developments, and this issue of Tax Talk is no exception. With foreign financial institutions expected to finalize their online registration with the IRS this year and withholding slated to begin July 1, 2014 – to name just a few of the looming FATCA deadlines – 2014 is crunch time for FATCA. Even as 2013 drew to a close, the Treasury concluded a plethora of Intergovernmental Agreements ("IGAs"). Not to be outdone, the Internal Revenue Service ("IRS") released a final version of the draft agreement that a foreign financial institution seeking to comply with FATCA must sign.¹ The IRS has also been busy working out some of the kinks in its FATCA registration website, which is used