On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) addressing various aspects of the withholding and information reporting regime commonly referred to as “FATCA”. The Proposed Regulations provide significant relief from potential withholding and compliance burdens that U.S. and non-U.S. financial institutions would otherwise be subject to under FATCA. The preamble to the Proposed Regulations announces that taxpayers may generally rely on the Proposed Regulations pending issuance of final regulations.
Read this post for a brief background of FATCA and a discussion of the most important aspects of the Proposed Regulations. For more information please contact any of the Proskauer tax lawyers listed on this post or your regular Proskauer contact.