In late January, the IRS issued a private letter ruling (P.L.R. 201504004) dealing with whether interests in a non-grantor trust and a partnership are considered to be in registered form, a precursor to qualification for payments thereon to the portfolio interest exemption. Although the ruling answers in the affirmative, it does not ultimately state whether the particular payments addressed in the ruling would be eligible for the portfolio interest exemption.
To qualify for the portfolio interest exemption, and avoid U.S. withholding tax on payments of U.S.-source interest to a foreign person, [...]Read more
This alert discusses the IRS’ new timelines, in Notice 2013-43, for FATCA compliance in response to numerous concerns voiced worldwide about the timing of FATCA implementation.
The full alert is provided on the Alston & Bird website: www.alston.com/advisories/FATCA-delay/
Written by Edward Tanenbaum, Partner, Federal & International Tax | Alston & Bird LLP