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Ann Birot-Salsbury
US Tax & Banking Committee Co-Chair
AAWE Paris

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Tracy Moede
US Tax & Banking Committee Co-Chair
AWC Hamburg

 

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On September 18, the IRS issued Notice 2015-66 which provides that Foreign Financial Institutions (FFIs) in countries with "Model 1" Intergovenmental Agreements (IGAs) will be treated as FATCA compliant, and not subject to FATCA withholding by the IRS, if those jurisdictions notify the IRS before September 30 of this year that they require more time to put their systems in place. In that case, the impending deadline will be extended to September 30, 2016.

Tax Controversy Watch has published an article explaining the change, with links to a list of countries affected.  Notice 2015-66 does not change the deadline for FFIs to report financial information to their local tax authority, which remains governed by the law of that country. The new rules do, however, provide additional time for non-compliant taxpayers to complete one of the various IRS disclosure programs and become compliant before the 2016 deadline.

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