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ARTICLE · 13 AUGUST 2014

U.S. Tax Developments Affecting Financial Institutions And Products

Fenwick
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Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes.

United StatesTax
William Skinner
William Skinner
Julia Ushakova-Stein
Julia Ushakova-Stein
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Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section 871(m). These new changes and their possible impact on affected taxpayers are discussed below.

FATCA Update

There have been a number of Foreign Account Tax Compliance Act (FATCA) related developments during the past year. As of June 2 2014, about 77,000 foreign financial institutions (FFIs) registered with the IRS to comply with FATCA and the list of FATCA-registered FFIs is expected to continue to grow. The implementation deadline is July 1 2014 and, as it approached, foreign entities were scrambling to determine if they are subject to FATCA and how to become FATCA compliant.

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