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withholding tax

International Tax Advisory: IRS Floats Updated Qualified Intermediary Agreement

July 15, 2016 By Edward Tanenbaum and Heather Ripley

Our International Tax Group discusses the IRS’s proposed update to the qualified intermediary agreement set to expire this year.

Click here to read the full advisory.

Filed Under: International Tax Advisory Tagged With: Action 13, FATCA, FFIs, Foreign Account Tax Compliance Act, foreign financial institutions, Form W-8, Form W-8IMY, IGA, intergovernmental agreement, IRS, limited branch, limited FFI, Notice 2010-46, Notice 2015-66, Notice 2016-42, OECD, Organisation for Economic Co-operation and Development, QDD, QI, QSL, qualified derivatives dealers, qualified intermediary agreement, qualified securities lender, Rev. Proc. 2000-12, Rev. Proc. 2014-39, Rev. Proc. 2014-47, Section 3406, Section 871(m), The 2014 QI Agreement, withholding tax

PATH Act Brings FIRPTA Changes

February 2, 2016 By Heather Ripley

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed December 18, 2015, introduces significant changes to the Foreign Investment in Real Property Tax Act (FIRPTA), particularly concerning REITs. The reforms are generally intended to make foreign investment in U.S. real estate more attractive, though some revenue-raising measures are thrown in the mix. Among the PATH Act's taxpayer-friendly FIRPTA updates: The ownership threshold for foreign “portfolio investors” in publicly traded REITs increases from 5% to 10%. These investors are exempt from FIRPTA tax [...]Read more

Filed Under: International - Corporate Tax Planning, International - Inbound, International Tax Advisory, RICs, REITs and other Special Entities Tagged With: FIRPTA, PATH Act, pension funds, portfolio investors, REIT, RIC, US real property, withholding tax

Scapegoats: How Foreign Taxpayers’ Credits & Refunds Could Be Limited by Withholding Agents’ Non-Compliance

May 19, 2015 By Heather Ripley

In Notice 2015-10 (the “Notice”), the IRS announced that it and the Treasury will issue regulations to limit credits or refunds for withholding taxes under Chapter 3 (Sections 1441-1443) and Chapter 4 (Sections 1471-1472, aka FATCA) to the amount actually deposited by withholding agents. The hope is that this “deposit limitation” will lessen the Treasury’s financial risk of crediting or refunding more tax, based on Form 1042-S reporting, than it collects or can collect. The Notice previews regulatory amendments to provide that a credit or refund for withheld tax is available only [...]Read more

Filed Under: International - Inbound Tagged With: chapter 3, chapter 4, FATCA, international tax advisory, Notice 2015-10, tax deposits, withholding agent, withholding tax

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