U.S. tax authorities issue final FATCA regulations *

USA - January 25 2013
On January 17, 2013, the U.S. Department of the Treasury (Treasury Department) and U.S. Internal Revenue Service (IRS) issued final Treasury…

Co-authors: Jamiel E. Poindexter, Stuart L Rosow, Martin T Hamilton, Mary B Kuusisto, Scott S Jones.

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United Kingdom and United States conclude FATCA intergovernmental agreement *

United Kingdom, USA - September 25 2012
On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account Tax Compliance Act ("FATCA").

Co-authors: Catherine Sear, Martin T Hamilton, Laurier W Beaupre, Scott S Jones, Jenny Wheater .

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ISDA publishes 2012 FATCA Protocol *

USA - August 28 2012
On August 15, 2012, the International Swaps and Derivatives Association (the "ISDA") opened the ISDA 2012 FATCA Protocol (the "FATCA Protocol") for adherence.

Co-authors: Stuart L Rosow, Martin T Hamilton, Charles W Stones.

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Deductibility of charitable contributions to LLCs wholly owned by charitable organizations *

USA - August 9 2012
On July 31, 2012, the Internal Revenue Service (the IRS) issued Notice 2012-52 (the Notice), providing long awaited confirmation that a charitable contribution to a limited liability company that is wholly owned by a charitable organization, and classified as a disregarded entity for U.S. federal income tax purposes (an SMLLC), will be treated as a contribution to a branch or division of the charitable organization.

Co-authors: Elizabeth M. Mills, Jacob I. Friedman, Gary Silber, Stuart L Rosow.

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IRS posts draft revised withholding forms conforming to FATCA *

USA - June 8 2012
The U.S. Internal Revenue Service ("IRS") has posted draft versions of revised Form W-8BEN, entitled "Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individual)" ("New W-8BEN"), as well as an entirely new Form W-8BEN-E, entitled "Certificate of Status of Beneficial Owner for United States Tax Withholding (Entities)" ("New W-8BEN-E", and together with the New W-8BEN, the "New Withholding Certificates").

Co-authors: Thomas J Leonardo, Arnold P May, Martin T Hamilton, Mary B Kuusisto, Laurier W Beaupre.

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