US Withholding Tax: Practical Implications of QI and FATCA by R. Mcgill

US Withholding Tax: Practical Implications of QI and FATCA

byR. Mcgill

Hardcover | October 31, 2013

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The US is the world's largest capital market - its withholding tax system is also the most complex. The QI regulations, which affect both qualified and non-qualified intermediaries, impose onerous documentation, withholding, and reporting obligations on financial firms receiving US-sourced income on behalf of their clients. Those signing QI agreements with the IRS also have stringent control and oversight obligations. Those who do not (NQIs) still have obligations, but are often unaware of them and thus liable for severe penalties. FATCA regulations on the other hand impose stringent disclosure and reporting requirements on US investors with foreign accounts as well as the institutions that provide those accounts. Triggered by concerns over tax evasion, the US authorities have widened the net for those who will be subject to these regulations and increased the severity of non-compliance penalties. Understanding these two systems, their interactions and the consequences of failure to comply, are essential tools for those dealing with the US trading markets.

US Withholding Tax gives practical insights for investors and intermediaries trying to comply with the US QI and FATCA tax regulations, guiding the reader through these complex regulations into how to meet these compliance burdens.

About The Author

ROSS MCGILL is a well known industry subject matter expert on US withholding tax and regulatory compliance. He sits on many industry bodies, international committees and associations, and he has worked with many of the world's largest financial institutions to support their operational compliance.

Details & Specs

Title:US Withholding Tax: Practical Implications of QI and FATCAFormat:HardcoverDimensions:352 pages, 9.02 × 5.98 × 0.03 inPublished:October 31, 2013Publisher:Palgrave Macmillan UKLanguage:English

The following ISBNs are associated with this title:

ISBN - 10:0230364616

ISBN - 13:9780230364615

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Extra Content

Table of Contents

Preface
Foreword
Acknowledgements
List of Tables and Charts
List of Abbreviations and Acroynyms
Introduction
PART I: THE QI REGULATIONS
Principles of Code Chapter 3
Contracts – the QI Agreement
Issues for Non-Qualified Intermediaries
Documentation
Presumption Rules
Withholding
Deposit of taxes
Information Reporting under Chapter 3
AUP
Penalties
Refunds
PART II: FATCA
Principles of Title V of the HIRE Act
The FFI Agreement
Terms and Definitions
Documentation Procedures
Waivers of privacy laws and treaty entitlements
Substantial Presence and Effective Control
Recalcitrant Accounts
Withholding and Pass Thru Payments
Information Reporting under Chapter 4
Transition Rules
Control, Oversight and Penalties
PART III: RELATED GLOBAL TAX INITIATIVES
OECD
European Union
Conclusion
Notes
Appendices
Bibliography
Index