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, Amanda H Nussbaum, Martin T Hamilton, Mary B Kuusisto, Laurier W Beaupre.

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IRS and Treasury Department publish anticipated FATCA guidance *

USA - February 9 2012
Proposed Regulations under the Foreign Account Tax Compliance Act Issued February 8, 2012.

Co-authors: Jamiel E. Poindexter, Stuart L Rosow, Amanda H Nussbaum, Mary B Kuusisto, Scott S Jones.

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IRS and Treasury Department publish anticipated guidance on "dividend equivalent" payments derived from equity swap arrangements *

USA - January 27 2012
On January 19, 2012, the U.S Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued rules governing when equity swaps and similar transactions would result in imposition of U.S. withholding tax under Section 871(m) and related Sections of the Internal Revenue Code of 1986, as amended (the "Code").

Co-authors: Michael Fernhoff, Amy G. Drais, Stuart L Rosow, Amanda H Nussbaum, Martin T Hamilton.

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Temporary relief from certain HIRE Act reporting requirements *

USA - June 29 2011
On June 21, 2010, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2011-55 (the “Notice”), providing temporary relief from certain information reporting requirements imposed under the Hiring Incentives to Restore Employment Act (the “HIRE Act”).

Co-authors: Raj Tanden, Michael Fernhoff, Stuart L Rosow, Amanda H Nussbaum, Martin T Hamilton.

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IRS issues preliminary guidance on the application of the Foreign Account Tax Compliance Act *

USA - September 24 2010
On August 27, 2010, the Internal Revenue Service (the IRS) issued Notice 2010-60 (the "Notice") establishing the framework for forthcoming regulatory guidance implementing the withholding and reporting provisions of the Foreign Account Tax Compliance Act ("FATCA").

Co-authors: Raj Tanden, Stuart L Rosow, Amanda H Nussbaum, Martin T Hamilton, Alan P Parnes.

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