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This document or presentation is not intended or written to be used,
and may not be used, for the purpose of avoiding pena...
Who are we?
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
Responsibilities of US persons in general
- What is a US Person?
• Passport holders
• Permanent residents
• Substantial pr...
Responsibilities of US persons in general
- What is a US Person?
Responsibilities of US persons in general
- Filing Threshold
http://www.irs.gov/pub/irs-pdf/p54.pdf
Responsibilities of US persons in general
- Reporting
• Other triggers –
• Interest in foreign entity
• FBARs
• Give or re...
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
Former FIFA Exec
• No idea whether the reports are true but online, it is
being alleged…
• That the IRS and Homeland Secur...
Former Guardian / UTC Exec
• Undercover sting
• Picked up at MIA
• According to a November 15th article in the New York
Ti...
Sovereign Management & Legal, Ltd
• Dec 14th 2014 press release on DOJ website -
http://www.justice.gov/usao/nys/pressrele...
Common Thread
• A recent Tax Notes Today article reports on the Criminal Fraud and Tax Controversy Conference
in Las Vegas...
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
FATCA
• The Foreign Account Tax Compliance Act (FATCA) is codified as Chapter 4 of the Internal Revenue Code. It represent...
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
FATCA – impact on Governments
• OECD’s Tax Information Exchange Agreements –
• FATCA was a rider to the 2010 HIRE Act but ...
FATCA – Governments that have signed
FATCA – Agreed in Principle
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
FATCA – implications for FFIs
• Firstly, they must register with the IRS directly. Form 8957
• Secondly, they must take ap...
What is a US Person?
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
Danger #1 – Non qualified
insurance policies
• Insurance policies can be treated as US qualified, US non-qualified or
a PF...
Danger #1 – Non qualified
insurance policies
• Section 7702(g) says the “income on the contract” must be reported as ordin...
Danger #1 – Non qualified
insurance policies
• Foreign life assurance or sickness and accident policies. Must pay
customs ...
Danger #2 - PFICs
• Enacted in 1986 to limit tax deferral by US investors in off shore funds
• Previously off shore funds ...
Danger #2 - PFICs
• To employ this punitive regime, the IRS requires shareholders of PFICs
to effectively report undistrib...
Danger #2 - PFICs
Danger #2 - PFICs
Danger #2 - PFICs
Danger #3 - FBARs
Danger #3 - FBARs
Danger #3 - FBARs
Danger #4 - FATCA
• FATCA stands for ‘‘Foreign Account Tax Compliance Act”
• The goal is to stop US tax evasion by –
• Req...
Danger #4 - FATCA
• The Foreign Account Tax Compliance Act (FATCA) is codified as Chapter 4 of the Internal Revenue Code. ...
Danger #4 - FATCA
Penalty - Up to $10,000 for failure to disclose and an additional $10,000 for each 30 days of non-filing...
Outline
• Responsibilities of US persons in general
• Citizenship vs residency based taxation
• Pay
• Report
• Recent medi...
TAX Amnesty
• Streamlined
• OVDP 2014
TAX Amnesty
“willfulness”
• Willfulness as a “voluntary, intentional violation of a known legal duty” was
“conclusively” a...
TAX Amnesty
• Streamlined –
• No penalty for offshore
• 5% penalty for domestic
• OVDP –
• 27.5%
• A 50% offshore penalty ...
TAX Amnesty
CIBC, Butterfield and Stanford
TAX Amnesty
U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance - http://www.ustaxprogram.com/ban...
TAX Amnesty
U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance
• Category 2 –
• Bank has reason ...
TAX Amnesty
• Outlook for 2015
Q&A
Appendices
Appendix – FATCA vs FBAR
Appendix – FATCA vs FBAR
Appendix – FATCA vs FBAR
Appendix – Tax Rates
Appendix – Tax Rates
Appendix – Obamacare Tax
Estimated Taxes?
Fixed, Determinable, Annual, Periodical (FDAP) Income
Effectively Connected Income (ECI)
Kovell Letters
• Without such an agreement, communication between the client and the accountant would not be
protected fro...
Impact – Democrats Abroad Survey of 6500 Americans abroad
Impact – types of accounts closed
Impact – value of accounts closed
Impact – closure stateside as well
Impact – refusal to open accounts
Impact – strained relationships
Impact – issues with employment
• Further Implications of FATCA
• US based brokerage firms
• Banks / Financial Institutions
• Annual Returns / Form 8938
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Understanding fatca icatt 07-01-15

  1. 1. This document or presentation is not intended or written to be used, and may not be used, for the purpose of avoiding penalties that may be imposed on the taxpayer.
  2. 2. Who are we?
  3. 3. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – FATCA • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – Non qualified insurance policies • Amnesty • Q&A
  4. 4. Responsibilities of US persons in general - What is a US Person? • Passport holders • Permanent residents • Substantial presence • Accidental Americans • NRA spouses who make a Sec 6013g election
  5. 5. Responsibilities of US persons in general - What is a US Person?
  6. 6. Responsibilities of US persons in general - Filing Threshold http://www.irs.gov/pub/irs-pdf/p54.pdf
  7. 7. Responsibilities of US persons in general - Reporting • Other triggers – • Interest in foreign entity • FBARs • Give or receive gifts
  8. 8. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – FATCA • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – Non qualified insurance policies • Amnesty • Q&A
  9. 9. Former FIFA Exec • No idea whether the reports are true but online, it is being alleged… • That the IRS and Homeland Security are looking • If the allegations are true, it may fall under the IRS Criminal Investigation (CI) team. This unit is comprised of approximately 3,500 employees worldwide, approximately 2,600 of whom are special agents whose investigative jurisdiction includes tax, money laundering and Bank Secrecy Act laws. The CI conviction rate is legendary. It is one of the highest in federal law enforcement. I understand that since CI’s inception in 1919 to the present, the conviction rate for Federal tax prosecutions has never fallen below 90%.
  10. 10. Former Guardian / UTC Exec • Undercover sting • Picked up at MIA • According to a November 15th article in the New York Times, at the IRS, dozens of undercover agents chase suspected tax evaders worldwide, by posing as tax preparers, accountants, drug dealers or yacht buyers and more, court records show. • Interestingly, undercover agents at the I.R.S., appear to have far more latitude than do those at many other agencies • I.R.S. rules say that, with prior approval, “an undercover employee or cooperating private individual may pose as an attorney, physician, clergyman or member of the news media.”
  11. 11. Sovereign Management & Legal, Ltd • Dec 14th 2014 press release on DOJ website - http://www.justice.gov/usao/nys/pressreleases/December14/Sovereign ManagementJohnDoeSummonsesPR.php • “Court Authorizes IRS To Issue Summonses For Records Relating To U.S. Taxpayers Who Used Services Of Sovereign Management & Legal, Ltd., To Conceal Offshore Accounts, Assets, Or Entities” • Sovereign is a multi-jurisdictional offshore services provider that offers clients, among other things, the formation and administration of anonymous corporations and foundations in Panama as well as offshore entities. Related services provided by Sovereign include the maintenance and operation of offshore structures, mail forwarding, the availability of virtual offices, re-invoicing, and the provision of professional managers who appoint themselves directors of the client’s entity while the client maintains ultimate control over the assets. • During the IRS’s investigation of Sovereign’s conduct, one taxpayer, making a voluntary disclosure of tax non-compliance to avoid prosecution, reported that Sovereign helped the taxpayer form an anonymous corporation in Panama that the taxpayer used to control assets without appearing to own them.
  12. 12. Common Thread • A recent Tax Notes Today article reports on the Criminal Fraud and Tax Controversy Conference in Las Vegas, sponsored by the American Bar Association Section of Taxation. Ajay Gupta, Offshore Enforcement to Remain Top Priority in 2015, 2014 TNT 240-6 (12/13/14)- • “[David Horton LB&I director for international compliance] warned of 'a lot more John Doe summonses' in the next 12 to 24 months, in other parts of the world and 'beyond banks.' The focus will be on intermediaries, he said, referring to those who promoted or facilitated transactions for stashing money abroad.“ • With a normal summons, the IRS seeks information about a specific taxpayer whose identity it knows. A John Doe summons allows the IRS to get the names of all taxpayers in a certain group. The IRS needs a judge to approve it, but recent IRS success may to lead to more. • A John Doe Summons is ideal for pursuing investors in tax shelters, account holders at financial institutions, attendees at an event, donors of real estate, etc. After sniffing out American taxpayers with UBS accounts, the IRS did the same with HSBC in India. But the IRS tells its own examiners to use a John Doe Summons only after trying other routes. The IRS Manual says it may be possible to obtain taxpayer identities without issuing a John Doe summons.
  13. 13. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – FATCA • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – Non qualified insurance policies • Amnesty • Q&A
  14. 14. FATCA • The Foreign Account Tax Compliance Act (FATCA) is codified as Chapter 4 of the Internal Revenue Code. It represents the Treasury Department's efforts to prevent U.S. taxpayers who hold financial assets in non-U.S. financial institutions (foreign financial institutions or FFIs) and other offshore vehicles from avoiding their U.S. tax obligations. • The intent behind the law is for foreign financial institutions (FFIs) to identify and report to the IRS U.S. persons holding assets abroad and for certain non-financial foreign entities (NFFEs) to identify their substantial U.S. owners. • In order to comply with the rules, FFIs are required to enter into an FFI agreement with the U.S. Treasury or comply with intergovernmental agreements (IGAs) entered into by their local jurisdictions. • U.S. withholding agents (USWAs) must document all of their relationships with foreign entities in order to assist with the enforcement of the rules. Failure to enter into an agreement or provide required documentation will result in the imposition of a 30% withholding tax on certain payments made to such customers and counter-parties. • Failure to impose the requisite withholding under FATCA requirements could result in significant financial exposure. • Impact on Governments, FFIs, NFFEs and US individuals
  15. 15. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – FATCA • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – Non qualified insurance policies • Amnesty • Q&A
  16. 16. FATCA – impact on Governments • OECD’s Tax Information Exchange Agreements – • FATCA was a rider to the 2010 HIRE Act but the OECDs model tax information exchange agreement dates back to at least 2002 • According to the OECD’s website, the purpose of the model agreement is to promote international co-operation in tax matters through exchange of information. It was developed by the OECD Global Forum Working Group on Effective Exchange of Information (“the Working Group”). The Working Group consisted of representatives from OECD Member countries as well as delegates from Aruba, Bermuda, Bahrain, Cayman Islands, Cyprus, Isle of Man, Malta, Mauritius, the Netherlands Antilles, the Seychelles and San Marino. • The Agreement grew out of the work undertaken by the OECD to address harmful tax practices. The lack of effective exchange of information is one of the key criteria in determining harmful tax practices. The mandate of the Working Group was to develop a legal instrument that could be used to establish effective exchange of information. The Agreement represents the standard of effective exchange of information for the purposes of the OECD’s initiative on harmful tax practices. • BEPS • Model 1 - require FFIs to report all FATCA-related information to their own governmental agencies, which would then report the FATCA-related information to the IRS. Some Model 1 IGAs are reciprocal, requiring the U.S. to provide certain information about residents of the Model 1 country to the Model 1 country in exchange for the information that country provides to the U.S. An FFI covered by a Model 1 IGA will not need to sign an FFI agreement, but it will need to register on the IRS’s FATCA Registration Portal or file Form 8957 • Model 2 - require FFIs to report information directly to the IRS. Under such IGA, FFIs will need to register with the IRS, and certain FFIs will sign a version of the FFI agreement modified to reflect the IGA.
  17. 17. FATCA – Governments that have signed
  18. 18. FATCA – Agreed in Principle
  19. 19. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – FATCA • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – Non qualified insurance policies • Amnesty • Q&A
  20. 20. FATCA – implications for FFIs • Firstly, they must register with the IRS directly. Form 8957 • Secondly, they must take appropriate actions to know their customers. KYC/AML. IT and HR implications • Thirdly, they must report the activity of US persons as required by local law. XML • (Our firm can assist with these responsibilities)
  21. 21. What is a US Person?
  22. 22. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – Non qualified insurance policies • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – FATCA • Amnesty • Q&A
  23. 23. Danger #1 – Non qualified insurance policies • Insurance policies can be treated as US qualified, US non-qualified or a PFIC • US qualified – if you have to ask… • PFIC – to be discussed later • US non qualified – • If underlying fund (in which the policy invests) are only available to the fund and not the general public • If policy holder doesn’t have the right to select from menu of funds • Then there should be no look-thru rule (not a PFIC)
  24. 24. Danger #1 – Non qualified insurance policies • Section 7702(g) says the “income on the contract” must be reported as ordinary income. • “Income on the contract” = increase in “net surrender value” during the taxable year + “cost of life insurance” for the year – premiums paid during the year. • “Net surrender value” = cash surrender value. • “Cost of life insurance” should roughly equate to the annual insurance cost of the contract – as opposed to the investment component. • We add this annual increase to the tax basis of the policy (in addition to total premiums). • Sickness payments should reduce this basis with any excess generating income. • We track policy basis with increases for premiums and taxable increases in cash value. No loss for the years when cash value goes down. • Everything fully disclosed in attachment to return
  25. 25. Danger #1 – Non qualified insurance policies • Foreign life assurance or sickness and accident policies. Must pay customs & excise tax at a rate of 1% of the premium paid per year. • This must be reported on Form 720 on a quarterly basis. • To be able to file Form 720 you will first require a Employer Identification Number . This can be obtained by completing form SS4. • Once you have your EIN you can now complete your 720 forms
  26. 26. Danger #2 - PFICs • Enacted in 1986 to limit tax deferral by US investors in off shore funds • Previously off shore funds had an advantage over domestic funds. No tax till distribution. • Post 1986, there is a level playing field for both domestic and off shore mutual funds. The U.S. puts the burden on the shareholder to determine their share of the income of the investment company. The tax code does not encourage U.S. persons to invest in mutual funds outside the U.S.
  27. 27. Danger #2 - PFICs • To employ this punitive regime, the IRS requires shareholders of PFICs to effectively report undistributed earnings via choosing to be taxed through one of three possible methods- 1. Section 1291 fund, 2. Qualified Election Fund, and 3. Mark to Market election.
  28. 28. Danger #2 - PFICs
  29. 29. Danger #2 - PFICs
  30. 30. Danger #2 - PFICs
  31. 31. Danger #3 - FBARs
  32. 32. Danger #3 - FBARs
  33. 33. Danger #3 - FBARs
  34. 34. Danger #4 - FATCA • FATCA stands for ‘‘Foreign Account Tax Compliance Act” • The goal is to stop US tax evasion by – • Requiring Foreign Financial Institutions (FFIs) and non-financial foreign entities (NFFEs) to provide information about financial accounts held by US taxpayers or foreign entities in which US taxpayers hold a substantial ownership interest. • Requiring US persons to report information about certain foreign financial accounts and offshore assets on Form 8938 and attach it to their income tax return, if the total asset value exceeds the appropriate reporting threshold. • In the future, requiring domestic entities to file Form 8938 if the entity is formed or used to hold specified foreign financial assets and the total asset value exceeds the appropriate reporting threshold. Until the IRS issues such regulations, only individuals must file Form 8938.
  35. 35. Danger #4 - FATCA • The Foreign Account Tax Compliance Act (FATCA) is codified as Chapter 4 of the Internal Revenue Code. It represents the Treasury Department's efforts to prevent U.S. taxpayers who hold financial assets in non-U.S. financial institutions (foreign financial institutions or FFIs) and other offshore vehicles from avoiding their U.S. tax obligations. • The intent behind the law is for foreign financial institutions (FFIs) to identify and report to the IRS U.S. persons holding assets abroad and for certain non-financial foreign entities (NFFEs) to identify their substantial U.S. owners. • In order to comply with the rules, FFIs are required to enter into an FFI agreement with the U.S. Treasury or comply with intergovernmental agreements (IGAs) entered into by their local jurisdictions. • U.S. withholding agents (USWAs) must document all of their relationships with foreign entities in order to assist with the enforcement of the rules. Failure to enter into an agreement or provide required documentation will result in the imposition of a 30% withholding tax on certain payments made to such customers and counter-parties. • Failure to impose the requisite withholding under FATCA requirements could result in significant financial exposure.
  36. 36. Danger #4 - FATCA Penalty - Up to $10,000 for failure to disclose and an additional $10,000 for each 30 days of non-filing after IRS notice of a failure to disclose, for a potential maximum penalty of $60,000; criminal penalties may also apply
  37. 37. Outline • Responsibilities of US persons in general • Citizenship vs residency based taxation • Pay • Report • Recent media coverage • Former FIFA Exec • Former Guardian Exec • Sovereign Management & Legal, Ltd • What is FATCA • Impact of FATCA – • Governments • FFIs • Individuals • Governments – • Model 1 • Model 2 • FFIs • Register • Report • Individuals • Danger #1 – Non qualified insurance policies • Danger #2 – PFICs • Danger #3 – FBARs • Danger #4 – FATCA • Amnesty • Q&A
  38. 38. TAX Amnesty • Streamlined • OVDP 2014
  39. 39. TAX Amnesty “willfulness” • Willfulness as a “voluntary, intentional violation of a known legal duty” was “conclusively” affirmed in Cheek v. United States 498 U.S. 192 (1991). • The two essential holdings of the Supreme Court were: 1. A genuine, good faith belief that one is not violating the Federal tax law based on a misunderstanding caused by the complexity of the tax law (e.g., the complexity of the statute itself) is a defense to a charge of "willfulness", even though that belief is irrational or unreasonable. 2. A belief that the Federal income tax is invalid or unconstitutional is not a misunderstanding caused by the complexity of the tax law,[16] and is not a defense to a charge of "willfulness", even if that belief is genuine and is held in good faith
  40. 40. TAX Amnesty • Streamlined – • No penalty for offshore • 5% penalty for domestic • OVDP – • 27.5% • A 50% offshore penalty applies if either a foreign financial institution at which the taxpayer has or had an account or a facilitator who helped the taxpayer establish or maintain an offshore arrangement has been publicly identified as being under investigation or as cooperating with a government investigation.
  41. 41. TAX Amnesty CIBC, Butterfield and Stanford
  42. 42. TAX Amnesty U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance - http://www.ustaxprogram.com/banks/ • Category 1 - Any Swiss bank currently under formal criminal investigation
  43. 43. TAX Amnesty U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance • Category 2 – • Bank has reason to believe that it may have committed tax-related offenses under U.S. Code title 18 (the U.S. criminal code); U.S. Code title 26 (the Internal Revenue Code); or monetary transaction offenses under Section 5314 (reporting requirements) or Section 5322 of title 31 of the U.S. Code, which governs financial activities in connection with an undeclared U.S.-related account. Category 2 Banks may request a nonprosecution agreement from the DOJ. Category 2 Banks also must agree to disclose information and evidence, perform certain due-diligence steps verified by an independent examiner, and pay a penalty that can range from 20% to 50% of the aggregate maximum value of their undisclosed U.S. accounts. • Participants include Union Bancaire Privee, the Geneva-based bank used by American Jordan Belfort, according to his memoir “The Wolf of Wall Street,” • Category 3 – Banks without undeclared U.S. clients that are applying for confirmation from the DoJ that they aren’t being investigated • Category 4 - Swiss banks with only local clients
  44. 44. TAX Amnesty • Outlook for 2015
  45. 45. Q&A
  46. 46. Appendices
  47. 47. Appendix – FATCA vs FBAR
  48. 48. Appendix – FATCA vs FBAR
  49. 49. Appendix – FATCA vs FBAR
  50. 50. Appendix – Tax Rates
  51. 51. Appendix – Tax Rates
  52. 52. Appendix – Obamacare Tax
  53. 53. Estimated Taxes?
  54. 54. Fixed, Determinable, Annual, Periodical (FDAP) Income
  55. 55. Effectively Connected Income (ECI)
  56. 56. Kovell Letters • Without such an agreement, communication between the client and the accountant would not be protected from discovery by the IRS because there is no accountant-client privilege under federal law. It is called a "Kovel Letter" because it is based on the case of United States v. Kovel, 296 F.2d 918 (2nd Cir. 1961). Practitioners, however, should review the recent case of United States v. Adlman, 68 F.3d 1495 (2nd Cir. 1995) for limitations on the "Kovel" doctrine. The letter can be used for both civil and criminal matters.
  57. 57. Impact – Democrats Abroad Survey of 6500 Americans abroad
  58. 58. Impact – types of accounts closed
  59. 59. Impact – value of accounts closed
  60. 60. Impact – closure stateside as well
  61. 61. Impact – refusal to open accounts
  62. 62. Impact – strained relationships
  63. 63. Impact – issues with employment
  64. 64. • Further Implications of FATCA • US based brokerage firms • Banks / Financial Institutions • Annual Returns / Form 8938

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