The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and enforce their own...
The Common Reporting Standard (CRS) is a global standard under which participating jurisdictions agree to exchange information about financial accounts held by...
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an...
What is the directive for administrative cooperation? The directive for administrative cooperation (DAC) (Directive 2011/16/EU) provides for wide-ranging exchange of...
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an...
This Practice Note considers the application of the Foreign Account Tax Compliance Act (FATCA) to UK Trusts, as implemented in the UK by the International Tax Compliance...
This Practice Note provides a broad overview of the application of Foreign Account Tax Compliance Act (FATCA) to employee incentive arrangements in the UK. After a brief...
This practice note provides a broad overview of the application of the Foreign Account Tax Compliance Act (FATCA) to fund structures in the UK. Where this note refers to...
This Practice Note provides a broad overview of the application of the Foreign Account Tax Compliance Act (FATCA) to loan agreements in the United Kingdom (UK). For a...
At a very high level, certain provisions of the US Internal Revenue Code of 1986, as amended (the Code), commonly known as FATCA, seek to encourage foreign (ie non-US)...
Background to FATCA FATCA is so-called because it derives from the Foreign Account Tax Compliance provisions in Subtitle A of Title V (offset Provisions) of the United...
This Practice Note provides a broad overview of: • the Intergovernmental Agreement between the UK and the US to improve international tax compliance and to implement...
This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs). For guidance on the OECD's Multilateral Convention on Mutual...
This tax 'tracker' tool displays the current status of both US FATCA and UK FATCA intergovernmental agreements (IGA). The tracker is split into five parts: • US...
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual Administrative...
What are the CDOT agreements? The UK entered into agreements with its three Crown Dependencies (CDs) (Guernsey, Jersey and the Isle of Man), together with its Overseas...
Contained within the Hiring Incentives to Restore Employment Act (HIRE Act), the Foreign Account Tax Compliance Act (FATCA) has three core elements: • enhanced due...
The Foreign Account Tax Compliance Act (FATCA) has three core elements: • enhanced due diligence • broader information reporting, and • a potential withholding tax on US...
The Hiring Incentives to Restore Employment Act (the HIRE Act) include provisions that give the US Internal Revenue Service (the IRS) administrative tools to: • detect,...
On 18 March 2010, the Hiring Incentives to Restore Employment Act (the HIRE Act) was signed into law. The provisions of the HIRE Act that address foreign account tax...
The Foreign Account Tax Compliance Act (FATCA) has three core elements: • enhanced due diligence • broader information reporting, and • a potential withholding tax on US...