On 28 September 2015, a new version of the CITT Compare Tool User Guide was uploaded. The new version includes a thorough introduction to the CITT News Blog with related news ticker as well as updates on the latest features of the Tool, including interactive maps in the Status and Reporting Overviews. Please take this opportunity to read more about the new features of the CITT Compare Tool and discover the numerous possibilities it offers.
A closer look at the new final regulations, and new temporary and proposed regulations – October 1 at 10:00 AM EDT (16:00CET)
On 18 September 2015, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 871(m) of the Internal Revenue Code (Link) concerning the imposition of US federal withholding tax on certain equity-linked instruments. The regulations present significant and specific implementation challenges for the financial markets.
A webcast will be held on 1 October 2015 at 10:00 EDT (16:00CET) in order to discuss the latest release by the US Department of the Treasury and the IRS of final and temporary regulations under section 871(m) of the Internal Revenue Code (Link)concerning the imposition of US federal withholding tax on certain equity-linked instruments (Registration – Link).
We will discuss:
- What issues should you consider? We’ll discuss:
- What is the story for the next two years?
- What are the new Delta and Substantial Equivalence tests and how do they work?
- What are the implications for both short and long parties?
With certain FATCA transitional and reporting deadlines set to expire on 30 September 2015, 31 December 2015, and 31 December 2016, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2015-66 (Link) announcing their intention to provide additional time for withholding agents and FFIs to comply with certain aspects of FATCA. In addition to extending certain transition rules, the Notice describes the compliance timeline for jurisdictions that have signed or agreed in substance to a Model 1 intergovernmental agreement (IGA), but have not yet brought the IGA into force.
See PwC Tax Insights
On 24 September 2015, the U.S. Competent Authority signed Competent Authority Arrangements (“CAAs”) with Australia (Link) and the U.K. (Link) according to the IGAs signed with these jurisdictions (Link to statement). The CAAs establish the procedures for the automatic exchange obligations and for the exchange of information. The CAAs signed with Australia and U.K. are the first ones but it is expected that more such Arrangements will be soon signed with the Competent Authorities of additional jurisdictions.
On 15 September 2015, the Government of Curaçao has approved a new ordinance that allows Curaçao Financial Institutions to comply with the requirements of the Foreign Tax Account Compliance Act (FATCA).
On 23 September 2015, the IRS issued an updated list of FATCA International Compliance Management Model (ICMM) frequently asked questions (Link). Two new questions were added; one on the TIN notification errors and what triggers them and one on how to submit a date of birth instead of a TIN when the latter is not available.
On 14 September 2015, the Federal Central Tax Office (BZSt) issued a new FATCA Infobrief (Link-German).
The IRS issued an updated list of FATCA International Compliance Management Model (ICMM) frequently asked questions on report notifications (Link). Several questions on FATCA 2.1 ICMM notification and record-level errors have been added.
The Cayman Department for International Tax Cooperation (“DITC”) announced that it is close to completing the validation of the FATCA reports it received. However, due to changes made to the US FATCA schema by the IRS, additional information should be included in submitted Reports. It consequently announced that the remedial action must be completed by 21 September 2015, 5:00pm EST.
On 11 September 2015, the Dutch Ministry of Finance published a draft law amending Dutch legislation in order to implement the Common Reporting Standard and the Directive on Administrative Cooperation. The Draft Law has been submitted to the Dutch Parliament for review.
Once approved, it will enter into force on 1 January 2016.