Introduction
Can a Vietnamese entity operating wholly in Vietnam be subject
to US tax liability and to US penalties? The answer is, yes. Some
of the exposed entities are securities firms, exchange traded
funds, fund management companies and commercial banks. There are
others.
The Foreign Account Tax Compliance Act
("FATCA") was enacted in 2010 to prevent
US
taxpayers and US corporations from evading US taxes by investing
their money through foreign financial institutions
("FFIs"). FATCA requires FFIs to
disclose account information of US individuals, US corporations,
and other foreign legal entities controlled by US individuals to
the US Internal Revenue Service
("IRS").