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Results: 1-10 of 34

U.S. Treasury and JapanSwitzerland announce they will negotiate toward a "third way" for FATCA compliance
  • Morrison & Foerster LLP
  • Japan, Switzerland, USA
  • July 9 2012

As we have previously reported, FATCA is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope


Draft Form W-8 released for FATCA implementation
  • Morrison & Foerster LLP
  • USA
  • July 9 2012

The IRS has released draft versions of revised Forms W-8 that allow foreign financial institutions (“FFIs”) to certify the status of beneficial accountholders that might otherwise be subject to withholding under FATCA


IRS announces phased implementation of FACTA
  • Morrison & Foerster LLP
  • USA
  • July 19 2011

On July 14, 2011, the Internal Revenue Service (“IRS”) and Treasury Department (“Treasury”) announced a phase-in schedule which effectively delays implementation of the Foreign Account Tax Compliance Act (“FATCA”) for one year and, in some cases, until 2015


IRS releases draft FFI Agreement
  • Morrison & Foerster LLP
  • USA
  • October 29 2013

On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI


2011 Report of Foreign Bank and Financial Accounts ("FBAR") due June 30
  • Morrison & Foerster LLP
  • USA
  • June 13 2012

We wanted to remind our clients that Treasury Form TD F-90 22.1 “Report of Foreign Bank and Financial Accounts” (commonly known as the “FBAR”) is due on June 30, 2012 with respect to the calendar year 2011


After months of anticipation, final FATCA regulations released
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations2 implementing


IRS rolls out FATCA intergovernmental agreements
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this


CoCo development
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

2012 was an active year for issuers and investors in contingent convertible bonds or "CoCo"s. Most significantly in Q4 Barclays priced a $3 billion


Press corner
  • Morrison & Foerster LLP
  • USA
  • March 31 2010

The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters


FACTA developments: Treasury concludes IGAS; IRS finalizes FFI Agreement
  • Morrison & Foerster LLP
  • USA
  • January 24 2014

With 2013 rapidly coming to a close, the Government worked feverishly to conclude IGAs with a host of new countries, release a final version of the