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United States - IRS Releases Initial Guidance on Withholding under Foreign Account Tax Compliance Act

United States
P. Carman
Derivatives & Financial Instruments, 2010 (Volume 12), No 6
25 November 2010
Notice 2010-60 clarifies the grandfather rules under the recent US Foreign Account Tax Compliance Act rules and gives preliminary guidance on what entities will or will not be treated as foreign financial institutions for the purposes of the rules. Notice 2010-60 also gives detailed guidance on the due diligence financial institutions will need to undertake to avoid being subject to the Foreign Account Tax Compliance Act withholding. However, there are many issues left unanswered that will hopefully be clarified in future guidance.
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