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ARTICLE · 03 JUNE 2014

Upcoming July FATCA Deadlines

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The July 1, 2014 deadline is approaching for the implementation of certain requirements of foreign financial institutions and certain non-financial foreign entities under FACTA.

United StatesTax
A&O Shearman
A&O Shearman
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The July 1, 2014 deadline for the implementation of certain requirements of foreign financial institutions and certain non-financial foreign entities under the Foreign Account Tax Compliance Act ("FATCA") is quickly approaching.

FATCA Overview

FATCA, the offshore account information reporting and withholding regime codified in sections 1471 through 1474 of the Internal Revenue Code and the Treasury Regulations promulgated thereunder, generally requires US financial institutions ("USFIs") and other withholding agents to withhold 30 percent of payments made to (1) foreign financial institutions ("FFIs") that have not agreed to report information with respect to their US person account-holders to the IRS and (2) non-financial foreign entities ("NFFEs") that are the beneficial owners of the payments and that do not report information with respect to their substantial U.S. owners to the withholding agent.1

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