2011 Foreign Account Tax Compliance Act
On April 8, 2011, the Internal Revenue Service (IRS) issued Notice 2011-34, which provides supplemental preliminary guidance on the preparation, documentation and withholding requirements under the Foreign Account Tax Compliance Act (FATCA), provisions of the Hiring Incentives to Restore Employment (HIRE) Act.
Some of the key areas addressed in this webcast:
- Revision of pre-existing account protocols to identify US accounts
- Initial guidance on passthru payments
- Revisions of account reporting obligations
- New guidance on Deemed Compliant Status
- Rules for the treatment of qualified intermediaries under section 1471
- Treatment of expanded affiliated groups
These changes will affect foreign banks and other financial institutions in any industry with an international operation. The question now is what’s a FFIs’ to do?
The Knowledge Group is assembling a panel of distinguished professionals and key regulators to help financial institutions, investment entities, and many other organizations understand the new regulations. The speakers will share their expert opinions in a two-hour LIVE Webcast.
- Passthru payments: what are they, how are they computed and what is their effect
- The impact of local law on account openings, account closing, withholding tax
- Deemed compliance payments
- How do trusts fit into FATCA
- Introduction - What is FATCA?
- Relevant Guidance
- Foreign Financial Institutions ("FFIs") - Definition
- Reporting Requirements Imposed on FFIs to Avoid Withholding
- Withholdable Payments
- Payments to Non-Financial Foreign Entities
- Effective Date
Sutherland Asbill & Brennan LLP
- Preexisting Accounts
Who Should Attend:
- International Tax Attorneys
- Tax Compliance Officers
- Senior Executives
- Financial Reporting Personnel
- Valuation Analysts
- General Counsel
- International Counsel
- Compliance Officers
- Ethics Officers
- Forensic Auditors
- Vice Presidents and Directors
- International Contract Managers
- Executives and Senior Officers of Banks, Thrifts, Credit Unions, and other Financial Institutions
- Financial Industry Analysts
- Service providers
- Financial Executives
- Tax Managers
- Enrolled Agents
- Other Interested Professionals
Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring.
Recently, Mr. Granwell has become active in advising investors from emerging countries engaged in cross-border transactions involving the United States and Europe and in advising financial institutions and their clients on international tax enforcement initiatives, including FATCA . He conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings, advising taxpayers on voluntary disclosures, assisting clients in obtaining regulatory changes and tax rulings and advising clients on tax legislation matters).
Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing …
Erika Litvak concentrates her practice on taxation, with special emphasis on international taxation. Erika assists individuals with off-shore income tax and estate planning, expatriation, pre-immigration planning, structuring investments in the United States, etc. Erika also assists U.S. and foreign business entities in cross-border transactions, merger and acquisitions, investments of U.S. entities abroad and investments of foreign entities in the United States, establishment of operations in the United States and abroad as well as with reporting and compliance issues in addition to any other aspect related to international taxation.
Areas of Concentration
- Pre-immigration planning
- Off-shore income tax and estate planning
- Investment in the United States
- Acquisition, maintenance and sale of U.S. real estate by foreigners
- Reporting and compliance
- Cross-border transactions
- Mergers and acquisitions
- U.S. companies investing or doing business abroad
- Starting or restructuring operations in the United States
- Foreign Account Tax Compliance Act (FATCA)
Erika Litvak concentrates her practice on taxation, with special emphasis on international taxation. Erika assists individuals with off-shore income tax …
Carol Tello is a member of Sutherland’s Tax Practice Group and focuses primarily on international tax matters. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters for both business entities and individuals. She is the author of the BNA TMP 915-3 " Withholding and Reporting Provisions Under Chapters 3 and 4," as well as "Summer's Last Gasp: Notice 2010-60 - Preliminary Guidance Under FATCA, 39 Tax Mgt Int'l Journal 760 (Dec. 2010) and "Reporting, Withholding, and More Reporting: HIRE Act Reporting and Withholding Provisions," 39 TM Int'l Journal 243 (May 2010). Much of her work has been for insurance companies in the cross-border context. She has particular experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters, and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions.
Her prior experience includes service in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). While at the IRS, she participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several Tax Court cases, and worked on various regulations and other guidance, including significant participation in developing regulations concerning the taxation of software transactions.
Carol Tello is a member of Sutherland’s Tax Practice Group and focuses primarily on international tax matters. Her practice includes …
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Greenberg Traurig is an international law firm with 1800 attorneys and governmental affairs professionals. Greenberg Traurig offers clients local resources and capabilities in 32 financial, business and government centers, including more U.S. locations than any other Top 10 law firm on The National Law Journal's 2010 NLJ 250.
Greenberg Traurig provides integrated legal services for clients worldwide. We offer a multidisciplinary team, including senior lawyers who have been the chief legal officers at major multinational companies and have spent years solving real-world problems in the business, political and legal arenas. We build teams around client needs, ensuring lean staffing, front-end planning and flexible billing, where appropriate. Our experience in multiple practice areas and our network of contacts in the United States and abroad position us to help clients achieve their objectives.
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