Expert Panelists Dissect & Discuss Impact of Proposed FATCA Regulations from U.S. Treasury
(Arlington, VA, February 8, 2012) The
U.S. Treasury has just released hundreds of pages detailing the new
proposed regulations under the Foreign Account Tax Compliance Act
("FATCA"). The information reporting and withholding rules will
have a pervasive impact on foreign financial institutions (FFIs)
and on non-financial foreign entities (NFFEs).
Navigating the New FATCA Proposed Regulations - What You Need to
Know (February 15) will feature IRS and Treasury
Department officials who participated in the drafting of the
proposed regulations as well as knowledgeable private
practitioners.
Registrants can expect a lively discussion and dissection of the
proposed regulations and an update on related enforcement issues.
There will be sufficient time for attendees to pose questions to
the panelists.
Topics to be covered include:
- How Will the
Treasury Department Rationalize FATCA with Foreign Law
Conflicts
- The Scope of
Withholdable Payments (including the inclusion of derivative
payments) and Exceptions
- Which Entities
Are FFIs and NFFEs
- The
Information and Reporting Obligations of Becoming a Participating
FFI or a Deemed Compliant FFI
- Considerations
to be taken into account in becoming Compliant or Non-Compliant
with FATCA
- How Will a US
Withholding Agent Know Whether to Withhold under Chapter 3 or
Chapter 4
- Special issues
for banks, funds, insurance companies and trusts
- Impact on U.S.
multinationals
- Treatment of
Passthru Payments
- The Compliance
Aspects of FATCA
- Other
Developments
Educational Objectives
- Understand the
impact of FATCA on foreign financial institutions (FFIs), and what
will be required for these institutions to prepare for FATCA's
coming into effect.
- Understand
what the category of "nonfinancial foreign entity" (NFFE) will mean
in practice.
- Understand the
scope of "withholdable payments," and how this characterization
will affect transactions with FFIs and NFFEs.
- Understand
what payments may be covered by more than one withholding regime,
and which regime to apply to payments with overlapping
obligations.
- Understand
information and reporting obligations when paying an FFI, a
"deemed-compliant FFI," or an FFE.
About the Speakers
Danielle Nishida joined the Internal
Revenue Service as an attorney in the Office of Chief Counsel,
International, in April 2009. She practices in income tax
withholding and Subpart F, and is a principal draftsperson of the
recent proposed regulations and other guidance under chapter 4
(FATCA). Prior to joining the Internal Revenue Service, she
was an attorney with Burt, Staples, and Maner, LLP. Danielle
is a graduate of Georgetown University (L.L.M, Taxation),
Southwestern Law School (J.D.), and the University of California at
Santa Barbara (B.A.).
Michael Plowgian is an Attorney-Advisor in
the Office of the International Tax Counsel at the Department of
the Treasury. Previously, he was an attorney in the tax group at
King & Spalding LLP, where his practice focused on a wide range
of domestic and international tax planning matters. Michael
received his J.D. from Harvard Law School, a M.A.L.D. from the
Fletcher School of Law and Diplomacy, and a B.A. from Denison
University.
Carol Tello is a partner in Sutherland Asbill &
Brennan LLP's Washington office and a member of its Tax Practice
Group where she focuses primarily on international tax matters. Her
practice includes a broad range of cross-border tax planning and
Internal Revenue Service (IRS) controversy matters for both
business entities and individuals. Much of her work has been for
insurance companies in the cross-border context.
Her prior experience includes service in the IRS Office of
Associate Chief Counsel (International) and as a Special Assistant
to the Assistant Commissioner (International). While at the IRS,
she participated in a number of income tax treaty negotiations, was
the IRS National Office adviser in several Tax Court cases, and
worked on various regulations and other guidance.
Alan Winston Granwell is an international tax
partner resident in DLA Piper's Washington, DC office. Mr.
Granwell's practice encompasses representing multinational
corporations on cross-border planning, to include acquisitions,
dispositions and business restructurings, IP migrations, services
arrangements, repatriation planning, international insurance,
international transportation, cross-border leasing, transfer
pricing and the use of bilateral tax treaties. He also advises
high-net-worth individuals on cross-border tax planning and
structuring.
Navigating the New Proposed FATCA regulations - What You Need to
Know takes place February 15, 2012, from 11:00 AM - 1:30
PM, (ET). To register for this webinar and obtain further
information about CLE and CPE credits, go to
http://www.bna.com/navigating-new-fatca-w12884907530/?utm_source=newswire&utm_medium=PR&utm_content=TM&utm_campaign=Webinar-02152012
or (in the U.S.) call 800.372.1033, menu Option 6, then Option 1.
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