FATCA: The Final Regulations

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FATCA experts Carol Tello, Alan Granwell, and their teams at Sutherland and DLA Piper will comb the 500 plus pages of technical detail supporting these final regulations and provide their critical findings in this recorded webinar. Will the IRS provide businesses with more unified definitions in the regulations? Will there be more coordination of the tax code Chapter 61 domestic reporting rules with the Chapter 3 rules regarding payments to foreign persons? Have insurance companies steered the IRS toward adopting definitions of insurance and annuity contracts used in the model IGAs incorporated in the final regulations? Will there be further relaxation and clarification of the due diligence rules, and further broadening of “deemed compliant” entities?

Educational Objectives
• Determine the likelihood of the IRS providing businesses with more unified definitions in the regulations 
• Determine whether there will be more coordination between the Chapter 61 domestic reporting rules and the Chapter 3 rules regarding payments to foreign persons 
• Discuss the influence that insurance companies had in the definitions of insurance and annuity contracts used in the model IGAs incorporated into the final regulations
• Anticipate any relaxation and clarification of the due diligence rules
• Anticipate the further expansion of entities that are “deemed compliant”



Alan Winston Granwell  is an international tax of counsel 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.

Recently, Mr. Granwell has become active in advising investors from emerging countries engaged in cross-border transactions involving the United States and Europe and in advising financial institutions and their clients on international tax enforcement initiatives, with special emphasis on the Foreign Account Tax Compliance Act. 


Peter Deblon is a tax counselor at the German Embassy. He has held this post since 2010. Prior 
to his position at the Embassy, Mr. Deblon worked at the German Ministry of Finance, where he 
coordinated federal tax legislation. He has also served as the desk officer for the state-owned 
German development bank KFW, the Office of the Parliamentary State Secretary at the Ministry, 
and the Officer of the Minister of Finance, Dr. Theo Waigel. His duties included monitoring of 
the Department of Capital Market and Financing of KFW, micro- and macroeconomic analysis 
of tax law changes, and management of the budget and financial relationship between the states 
and federal government.

Prior to his service for the German Ministry of Finance, Mr. Deblon served as a research 
assistant to Dr. Friedman, Chairman of the Audit Committee of the German Bundestag. Mr. 
Deblon also worked as an audit assistant at a tax consulting firm. Mr. Deblon has a degree in 
Business with a focus on company auditing, tax law, and finance.


With a career that spans both government and private practice, Carol Tello helps multinational companies and individuals navigate the complex and rigorous realm of international taxation. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters, including compliance with the Foreign Account Tax Compliance Act (FATCA).

Balancing the concurrent goals of minimizing tax consequences and complying with the law, Carol brings experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions.


Lorraine White works for the Bank of New York Mellon as head of EMEA custody tax and US tax services where she provides custody tax technical support to the Banks Asset Servicing groups and clients in the EMEA region.

Lorraine has had an extensive career in Asset Servicing, primarily focusing on custody tax matters, Lorraine has been heavily involved with a number of trade associations and their work on FATCA, most notably that of the UKs British Bankers Association where she also currently chairs its International Custodian Tax Liaison Group.

Lorraine is an active participant in global initiatives, focusing on simplification and harmonisation of tax relief and tax compliance procedures for cross border portfolio investors, notably the work of the EU Commission and the OECDs TRACE Group.