Hansuke

This Practice Note provides a broad overview of the application of Foreign Account Tax Compliance Act (FATCA) to employee incentive arrangements in the UK.

This Practice Note provides a broad overview of the application of the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) to fund structures in the UK. It considers the position in the UK under the Intergovernmental Agreement (IGA) between the UK and the US (the UK:US IGA) and The International Tax Compliance Regulations 2015, SI 2015/878. This Practice Note is produced in partnership with.

The US tax rules known as FATCA require foreign financial institutions (FFIs) to provide certain information to the US Internal Revenue Service (IRS) regarding their account holders so as to avoid being subject to a 30% withholding tax on certain payments received by the FFI, unless the FFI satisfies certain conditions. The critical FATCA definitions of an FFI and an account holder can include pension schemes (and trustees) and their members respectively. This Practice Note considers the application of FATCA to UK-registered pension schemes and certain unregistered schemes that provide similar pension benefits.

This Practice Note summarises the Standard for Automatic Exchange of Financial Account Information, developed by the OECD with G20 countries. Finalised in July 2014, the Standard represents the international consensus on automatic exchange of financial account information for tax purposes, on a reciprocal and annual basis. It sets out the financial account information to be exchanged, the Financial Institutions (FI) required to report, the different types of accounts and taxpayers covered, as well as common due diligence procedures to be followed by FIs. The Standard comprises a Model Competent Authority Agreement (Model CAA) and the Common Reporting and Due Diligence Standard (CRS) together with commentaries and annexes. The standard has been implemented into UK law via the International Tax Compliance Regulations 2015, SI 2015/878. This Practice Note was produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited.

This Practice Note provides a broad overview of the application of FATCA in the UK. It is one of a series of Practice Notes explaining the tax consequences in the UK arising from FATCA. It considers the Intergovernmental Agreement (IGA) between the UK and the US (the UK:US IGA) and the UK’s domestic implementation regulations, the International Tax Compliance Regulations 2015, SI 2015/878. This Practice Note is produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited.

This Practice Note considers some frequently asked questions in relation to the agreements entered into between the UK and its crown dependencies and overseas territories for the exchange of information on financial accounts, known as Crown Dependency/Overseas Territory (CDOT) Agreements. It deals with reporting of information relating to periods up to the end of 2016, reported in 2017, before CDOT was superseded by the Common Reporting Standard (CRS). This Practice Note was produced in partnership with Ali Kazimi of Hansuke Consulting.