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Past Event
15 September 2011


  • Thomas J. Delaney
    T +1 202 263 3216
  • Jonathan A. Sambur
    T +1 202 263 3256

Update on the Recently Enacted FATCA and its Implications for Non-US-Based Financial Intermediaries

The US Department of the Treasury and the Internal Revenue Service are beginning to implement the provisions of the Foreign Account Tax Compliance Act (FATCA). FATCA includes numerous far-reaching international tax provisions that will impose new reporting and certification obligations on a wide range of non-US financial intermediaries (including non-US banks, non-US investment funds and collective investment vehicles, non-US CLOs and CDOs and non-US insurance companies) that own US investments.

More significantly, FATCA will affect non-US intermediaries, even if those intermediaries have no US clients. Thus, many non-US entities that perform financial intermediary functions will, for the first time, be forced to interact with the IRS and must now ensure their operations are conducted in line with yet-to-be-determined US regulatory requirements in order to avoid being subjected to significant withholding taxes.

Please join us as Thomas Delaney and Jonathan Sambur of Mayer Brown discuss the evolving IRS FATCA guidance and its significance for financial institutions that are trying to anticipate the impact that FATCA compliance will have on their operations. The speakers will also discuss potential future developments in the guidance process.

Of Related Interest

An Overview of the Recently Enacted Foreign Account Tax Compliance Act (FATCA) and its Implications for Non-US Based Financial Intermediaries
Teleconference recording: 4/15/2010

Mayer Brown's Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm's global resources from multiple practices and offices, the Initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.

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