Treasury and the IRS issued temporary relief procedures in Notice 2023-11 for a foreign financial institutions (FFI) that is subject to a Model 1 intergovernmental agreement (IGA) jurisdiction.
Model 1 FFIs that follow the procedures set forth in the Notice will not be in significant non-compliance with their obligations under an applicable Model 1 IGA solely because of a failure to report a required US taxpayer identification number (TIN) in relation to “preexisting accounts”.
Welcome to our first quarter issue of the Private Wealth Newsletter. Our featured insight for this issue is a discussion of the passage of the Corporate Transparency Act by the United States to introduce federally-mandated beneficial ownership reporting obligations for US corporations and limited liability companies. We also include insights…
Click here to request the latest edition of this newsletter. Feature Malaysia: Wealth management and tax planning in the wake of COVID-19 Case Summaries Brazil Private Letter Ruling No. 41 of 31 March 2020 — tax treatment of trust distributions to Brazilian beneficiaries France Wealth tax — The refusal to…
Read publication We are pleased to enclose the June issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features Proposed Regulations on Deductibility of Certain Fines and Penalties and Related Information Reporting Retirement Relief Provisions Accessible to More Taxpayers and…
Read publication We are pleased to enclose the March issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features an update on the tax payment deadline, state and local tax effects of COVID-19, a discussion on the FDII regime, the…
On 21 March 2019, the US Internal Revenue Service (IRS) issued final regulations (the Final Regulations) relating to FATCA verification and certification requirements. FATCA Sponsoring entities, trustees of trustee documented trusts (TDTs) and compliance financial institutions should review their FATCA compliance under the Final Regulations to ensure compliance. The Final…