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Legal Briefing
FACTA – why non-US financial entities should sit up and pay attention
Practice Area: Regulation and Compliance
Sector: Investment Banking
Jurisdiction: USA
Published: 20 July 2011
Law Firm: DLA Piper
Overview
The US Internal Revenue Service (IRS) has issued two notices setting forth their preliminary thinking as to how the Foreign Account Tax Compliance Act will be implemented. The IRS is in the process of drafting regulations to provide more comprehensive guidance. This briefing provides a brief overview of FACTA, summarizes two significant issues that may affect the implementation of FACTA, briefly summarizes Notice 2010-60, contains a more detailed overview of Notice 2011-34 and suggests how affected entities should proceed to decide how to navigate FACTA.
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