Learn more about the Foreign Account Tax Compliance Act (FATCA), including FFI, NFFE, GIIN, FATCA Timeline, and more, from the International Tax Partners at Citrin Cooperman.
View the recorded FATCA webinar presentation here: http://www.citrincooperman.com/Webinars/FACTA-Webinar.aspx
www.citrincooperman.com
Global and local Implementation
Timeline for early adopters
Integration of CRS into the Cyprus Tax National Law
Entity Classification
Reporting/Non-reporting Financial Institutions (FI)
Defining FI
Depository Institutions
Specified Insurance Company
Custodial Institution
Investment Entities
Defining Non-Financial Institutions (NFEs)
Active NFEs
Criteria of being considered a NFE
Based on Income and Assets
‘Substantially all ’ - Holding Company
‘Treasury Centre’ – Financing Company
Under CRS definitions & examples
Non-profit Organisations
Reporting and Timing
Sanctions for non-Compliance
DrCompliance
A related-party transaction is a business deal or arrangement between two parties who are joined by a special relationship prior to the deal.
The update to NIST Special Publication 800-63 Revision 3 covers guidelines on digital identity management, identity proofing and authentication of users working with government IT systems over open networks – and serves as de facto guidance far beyond government and into many industries that are depending on secure user authentication.
Part of the guidelines recommend higher-assurance authentication, including the use of multi-factor authentication with public key cryptography, where private keys are tightly bound to the device. This, of course, is the core of the FIDO approach which has been implemented in over 300 FIDO certified products worldwide that are powering authentication solutions from top service providers such as Google, Facebook, Aetna and more.
In this presentation, experts review the NIST guidelines and their relationship to FIDO Authentication.
This presentation offers users a simple guide to learning the basic structure of hedge funds. Guiding users through hedge fund structures, covering topics such as:
• Hedge funds’ typical partnership structure
• Organizational structure at many hedge funds
• Due to their structure, only certain types of investors can invest with hedge funds
• The role of portfolio managers
• The typical role of general counsels, auditors, and administrators at hedge funds
• How prime brokers interact with hedge funds
• Executing brokers and their role in the hedge fund industry
• Fee structure at hedge funds
Learn more about the global hedge fund industry at: www.hedgefundfundamentals.com.
Global and local Implementation
Timeline for early adopters
Integration of CRS into the Cyprus Tax National Law
Entity Classification
Reporting/Non-reporting Financial Institutions (FI)
Defining FI
Depository Institutions
Specified Insurance Company
Custodial Institution
Investment Entities
Defining Non-Financial Institutions (NFEs)
Active NFEs
Criteria of being considered a NFE
Based on Income and Assets
‘Substantially all ’ - Holding Company
‘Treasury Centre’ – Financing Company
Under CRS definitions & examples
Non-profit Organisations
Reporting and Timing
Sanctions for non-Compliance
DrCompliance
A related-party transaction is a business deal or arrangement between two parties who are joined by a special relationship prior to the deal.
The update to NIST Special Publication 800-63 Revision 3 covers guidelines on digital identity management, identity proofing and authentication of users working with government IT systems over open networks – and serves as de facto guidance far beyond government and into many industries that are depending on secure user authentication.
Part of the guidelines recommend higher-assurance authentication, including the use of multi-factor authentication with public key cryptography, where private keys are tightly bound to the device. This, of course, is the core of the FIDO approach which has been implemented in over 300 FIDO certified products worldwide that are powering authentication solutions from top service providers such as Google, Facebook, Aetna and more.
In this presentation, experts review the NIST guidelines and their relationship to FIDO Authentication.
This presentation offers users a simple guide to learning the basic structure of hedge funds. Guiding users through hedge fund structures, covering topics such as:
• Hedge funds’ typical partnership structure
• Organizational structure at many hedge funds
• Due to their structure, only certain types of investors can invest with hedge funds
• The role of portfolio managers
• The typical role of general counsels, auditors, and administrators at hedge funds
• How prime brokers interact with hedge funds
• Executing brokers and their role in the hedge fund industry
• Fee structure at hedge funds
Learn more about the global hedge fund industry at: www.hedgefundfundamentals.com.
This slide is all about IFRS 2 share based payment. You can find its content summary & examples here. The link to access the video lectures is inserted in the final slide.
MFA's new educational presentation explains the fees associated with hedge funds and how they are used by hedge fund managers. Generally, hedge fund structures incur management fees and performance fees. Other terms explored in the presentation include high-water marks and hurdle rates. Of course, all hedge fund fees charged to any particular investor are based on contractual terms agreed to by the fund manager and the investor. While there is no such thing as a “standard” fee, there are a number of general terms that apply to hedge fund fees.
Bypassing Port-Security In 2018: Defeating MacSEC and 802.1x-2010Priyanka Aash
"Existing techniques for bypassing wired port security are limited to attacking 802.1x-2004, which does not provide encryption or the ability to perform authentication on a packet-by-packet basis [1][2][3][4]. The development of 802.1x-2010 mitigates these issues by using MacSEC to provide Layer 2 encryption and packet integrity check to the protocol [5]. Since MacSEC encrypts data on a hop-by-hop basis, it successfully protects against the bridge-based attacks pioneered by the likes of Steve Riley, Abb, and Alva Duckwall [5][6].
In addition to the development of 802.1x-2010, improved 802.1x support by peripheral devices such as printers also poses a challenge to attackers. Gone are the days in which bypassing 802.1x was as simple as finding a printer and spoofing address, as hardware manufacturers have gotten smarter.
In this talk, we will introduce a novel technique for bypassing 802.1x-2010 by demonstrating how MacSEC fails when weak forms of EAP are used. Additionally, we will discuss how improved 802.1x support by peripheral devices does not necessarily translate to improved port-security due to the widespread use of weak EAP. Finally, we will consider how improvements to the Linux kernel have made bridge-based techniques easier to implement and demonstrate an alternative to using packet injection for network interaction. We have packaged each of these techniques and improvements into an open source tool called Silent Bridge, which we plan on releasing at the conference."
Conduct Risk. Assessing risk and identifying cultural drivers for clear defin...Compliance Consultant
Conduct Risk is sweeping the financial services world and catching many risk manager out as there is still a lack of understanding.
Our Compliance Manual is available at http://bit.ly/ComplianceManualTemplate
Risk management need to determine the corporate risk philosophy and appetite. To assess or understand the risk philosophy, try to comprehend the organisation's culture, values and environment. The way business operations are conducted on a daily basis and the organisation’s strategy are typically good indicators where you can find the company risk philosophy. Assess whether business has an aggressive, innovative, typical or conservative attitude towards risks for achieving business goals.
Risk appetite is simply the amount of risk which the organisation is willing to take to undertake business activities and achieve the business objectives, where Conduct Risk is concerned this has to include good customer outcomes. A simple question to ask the board of members could be “What amount of reported mismanagement or public uproar would make you uncomfortable if it appeared in the business newspapers?”
Consolidate the various risk exposures from the risk department's identified risks and present them to the board. Finally, assess whether the company’s internal perception and rhetoric on risk philosophy and appetite are consistent with the board and other stakeholder's viewpoints. Realign the two where required to prepare the annual strategy.
Build Your Framework.
Deploying new WAN services can take a long time and require a significant up-front capital investment. The software-defined nature of SD-WAN enables service agility, rapid rollout, and instant-on WAN that the Service Provider can immediately benefit from. This accelerates the time to market and time to revenue.
Customer Due Diligence: Improving Screening Processes for OFAC Entities and O...SHAUN HASSETT
Update on current OFAC Screening Requirements and How to Improve the Screening Processes as part of your overall Customer Due Diligence Program.
For more information about this topic, please contact SHAUN HASSETT at due_diligence@att.net
This slide is all about IFRS 2 share based payment. You can find its content summary & examples here. The link to access the video lectures is inserted in the final slide.
MFA's new educational presentation explains the fees associated with hedge funds and how they are used by hedge fund managers. Generally, hedge fund structures incur management fees and performance fees. Other terms explored in the presentation include high-water marks and hurdle rates. Of course, all hedge fund fees charged to any particular investor are based on contractual terms agreed to by the fund manager and the investor. While there is no such thing as a “standard” fee, there are a number of general terms that apply to hedge fund fees.
Bypassing Port-Security In 2018: Defeating MacSEC and 802.1x-2010Priyanka Aash
"Existing techniques for bypassing wired port security are limited to attacking 802.1x-2004, which does not provide encryption or the ability to perform authentication on a packet-by-packet basis [1][2][3][4]. The development of 802.1x-2010 mitigates these issues by using MacSEC to provide Layer 2 encryption and packet integrity check to the protocol [5]. Since MacSEC encrypts data on a hop-by-hop basis, it successfully protects against the bridge-based attacks pioneered by the likes of Steve Riley, Abb, and Alva Duckwall [5][6].
In addition to the development of 802.1x-2010, improved 802.1x support by peripheral devices such as printers also poses a challenge to attackers. Gone are the days in which bypassing 802.1x was as simple as finding a printer and spoofing address, as hardware manufacturers have gotten smarter.
In this talk, we will introduce a novel technique for bypassing 802.1x-2010 by demonstrating how MacSEC fails when weak forms of EAP are used. Additionally, we will discuss how improved 802.1x support by peripheral devices does not necessarily translate to improved port-security due to the widespread use of weak EAP. Finally, we will consider how improvements to the Linux kernel have made bridge-based techniques easier to implement and demonstrate an alternative to using packet injection for network interaction. We have packaged each of these techniques and improvements into an open source tool called Silent Bridge, which we plan on releasing at the conference."
Conduct Risk. Assessing risk and identifying cultural drivers for clear defin...Compliance Consultant
Conduct Risk is sweeping the financial services world and catching many risk manager out as there is still a lack of understanding.
Our Compliance Manual is available at http://bit.ly/ComplianceManualTemplate
Risk management need to determine the corporate risk philosophy and appetite. To assess or understand the risk philosophy, try to comprehend the organisation's culture, values and environment. The way business operations are conducted on a daily basis and the organisation’s strategy are typically good indicators where you can find the company risk philosophy. Assess whether business has an aggressive, innovative, typical or conservative attitude towards risks for achieving business goals.
Risk appetite is simply the amount of risk which the organisation is willing to take to undertake business activities and achieve the business objectives, where Conduct Risk is concerned this has to include good customer outcomes. A simple question to ask the board of members could be “What amount of reported mismanagement or public uproar would make you uncomfortable if it appeared in the business newspapers?”
Consolidate the various risk exposures from the risk department's identified risks and present them to the board. Finally, assess whether the company’s internal perception and rhetoric on risk philosophy and appetite are consistent with the board and other stakeholder's viewpoints. Realign the two where required to prepare the annual strategy.
Build Your Framework.
Deploying new WAN services can take a long time and require a significant up-front capital investment. The software-defined nature of SD-WAN enables service agility, rapid rollout, and instant-on WAN that the Service Provider can immediately benefit from. This accelerates the time to market and time to revenue.
Customer Due Diligence: Improving Screening Processes for OFAC Entities and O...SHAUN HASSETT
Update on current OFAC Screening Requirements and How to Improve the Screening Processes as part of your overall Customer Due Diligence Program.
For more information about this topic, please contact SHAUN HASSETT at due_diligence@att.net
Seeing opportunities in IoT but finding it hard to define its value for your business? Codit helps you explore new business models, increase business efficiency or optimize your processes with IoT. Disover it all in this presentation about Azure IoT
Un programma altamente innovativo realizzato attraverso una serie di sensori e telecamere con l’obiettivo di verificare e controllare il territorio senza mai venir meno, è stato più volte sottolineato, alle disposizioni di legge in materia di privacy
FATCA Compliance: Riding a Roller Coaster of Regulatory ChangeBroadridge
FATCA will impose new due diligence, withholding, and reporting requirements on financial institutions. This paper outlines the significant regulatory change FATCA brings to provide the IRS with an increased ability to detect U.S. tax evaders—specifically, those among U.S. “persons” (individuals or entities) who maintain foreign accounts and investments either directly or indirectly, through their ownership in foreign entities.
Presented by Jon Kutner, hyperWALLET General Counsel, at the 2014 DSA Global Regulatory Conference.
The Foreign Accounts Tax Compliance Act (FATCA) should be on the radar screen of every DSA member company. This presentation will begin with a background on the legislation and how it is being implemented globally, followed by a summary of how the FATCA rules interact with Section 1441/Non-resident alien withholding rules affecting DSOs paying distributors in foreign countries. The presentation will also cover FATCA issues affecting DSOs with business entities in foreign countries, and provide some suggestions for multinationals to prepare for FATCA due diligence requests from their foreign financial institutions.
Do Your Withholding Processes Comply with FATCA?CBIZ, Inc.
The recently enacted Foreign Account Tax Compliance Act (FATCA) added a chapter to the Internal Revenue Code designed to prevent U.S. persons from using offshore accounts and investments to evade U.S. tax. Effective July 1, 2014, any person making a payment of U.S. source income to either a Foreign Financial Institution (FFI) or a Non-Financial Foreign Entity (NFFE) must consider whether it is subject to FATCA.
The Department of Treasury issued additional guidance on FATCA compliance including final versions of various disclosure forms, statement of specified foreign financial assets, and new regulations for foreign financial institutions - O'Connor Davies - New York CPA Firm, New York City
The 440 page LexisNexis® Guide to FATCA Compliance was designed in consultation, via numerous interviews and meetings, with government officials, NGO staff, large financial institution compliance officers, investment fund compliance officers, and trust companies, from North and South America, Europe, South Africa, and Asia, and in consultation with contributors who are leading industry experts. The contributors hail from several countries and an offshore financial center and include attorneys, accountants, information technology engineers, and risk managers from large, medium and small firms and from large financial institutions. Thus, the challenges of the FATCA Compliance Officer are approached from several perspectives and contextual backgrounds. See http://www.lexisnexis.com/store/catalog/booktemplate/productdetail.jsp?pageName=relatedProducts&prodId=prod19190327
This 28 chapter Guide contains three chapters written specifically to guide a financial institution's lead FATCA compliance officer in designing a plan of internal action within the enterprise and interaction with outside FATCA advisors with a view of best leveraging available resources and budget [see Chapters 2, 3, and 4]. Sample chapter available at http://www.lexisnexis.com/store/images/samples/9780769853734.pdf
Foreign Bank Account Report (FBAR) is a step taken by the US to detect any sort of fraud or deception related to tax and hiding of money in different seaward accounts.
C-Suite Snacks Webinar Series: Modern Decision SupportCitrin Cooperman
The role of finance continues to evolve in response to the ever-changing business environment. In order to keep your business agile, it is important to make sure that you're fully benefiting from a best-in-class FP&A function.
During this C-Suite Snacks webinar, Dominic DiBernardo, Partner and Corporate Performance Management Practice Leader, discusses what modern decision support looks like and the ingredients for a great financial planning and analysis (FP&A) function.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
C-Suite Snacks Webinar Series: Building an Advisory BoardCitrin Cooperman
Many private businesses evolve to the point where adding an advisory board can be a significant resource for the owners and senior leadership team, as they accelerate growth and profitability in their companies.
During this C-Suite Snacks webinar, Mark Dailey, a partner at Newport, LLC and seasoned advisory board expert, discusses when you should evaluate building a board, the leading practices and board structures you should consider, and the responsibilities that come with running your board.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
C-Suite Snacks Webinar Series: Prepping Your Company's Financials for SaleCitrin Cooperman
The business acquisitions market is booming and it’s a seller’s market out there! What can you do NOW to make sure that your business is ready?
Join us at our upcoming C-Suite Snacks webinar as Peter Colgan, Transaction Advisory Services Practice manager, discusses what business leaders find most challenging about preparing their financials for sale and how to efficiently conquer those challenges through the lens of a sell-side financial due diligence.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
Preparing for the new lease accounting standard can seem like a daunting task. In this webinar, we reviewed how you can handle and prepare to navigate your business through the new lease accounting standard in 2022.
Lease Accounting: Preparing Your Business for 2022Citrin Cooperman
Making a smooth transition to the new lease accounting standards and putting new practices in place for the future is a top priority for any business as they plan for 2022. During this webinar session, we reviewed how you can handle and prepare to navigate your business through the new lease accounting standards.
Topics included:
- What private companies should think about for 2022
- How the lease accounting standards can impact your financial
statements, financial covenants, and taxes
- Identifying opportunities for your business due to the new lease
accounting standards
High Net Worth Webinar Series - Tax Planning and Update for 2022Citrin Cooperman
As 2021 comes to an end, business owners and individuals are seeking opportunities to maximize their savings through year-end tax planning. This webinar session will help you navigate the many complexities, obstacles, and impending tax landscape changes that the 2021 tax year brings to the table and what 2022 has in store.
C-Suite Snacks Webinar Series: The Talent Wars - Can Benefits Be Your Secret ...Citrin Cooperman
In today’s candidate-driven job market, offering a competitive benefits package can significantly improve your company’s success in both attracting and retaining talent. In this webinar session, Shaun Gagnon, president and managing partner of Cambridge Insurance Advisors, shares his insights on maximizing your employee benefits to attract employees and combat the talent shortage.
Topics included:
• Trends in open enrollment and wellness fairs
• Popular and practical benefits
• The war on talent
• Cost increases and how to deal with them
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
High Net Worth Webinar Series - The Business of Digital Assets & BlockchainCitrin Cooperman
The recent rise of Bitcoin and digital assets has created significant new opportunities and challenges for investors. This emerging asset class is transforming both the technology and finance industries. In this session, you will learn about Bitcoin, its progeny, the emerging use cases for digital assets, and how investors are getting involved.
High Net Worth Webinar Series - Estate Planning Strategies and UpdatesCitrin Cooperman
There’s much uncertainty in the world of estate planning for high net worth individuals and their families. With numerous legislative proposals that would drastically alter the current estate planning landscape, listen in as our Trust and Estate Services Practice team discusses: various proposals, including those in Congress and the Biden Administration’s Green Book, estate and gift planning strategies for the remainder of tax year 2021, and more.
Showtime for Shuttered Venue Operators Grant (SVOG) RecipientsCitrin Cooperman
We discuss the ever-changing guidance around the conditions attached to the distribution of these funds and the specific requirements your organization needs to execute.
C-Suite Snacks Webinar Series: A Year Like No Other - Manufacturing and Distr...Citrin Cooperman
Our second annual Manufacturing and Distribution Pulse Survey Report explores the impact of the pandemic on the industry, and how businesses have pivoted to survive, including managing new product offerings, technology implementation, and supply chain disruptions.
During this webinar session, we discussed how 200 leaders of M&D companies, ranging from $20 million to over $1 billion in revenue, responded to our survey.
Topics included:
• How COVID-19 has accelerated the 4th Industrial Revolution
• Product sourcing changes
• Business pivots and what made them successful
Manufacturing & Distribution Update: The Economic Impact on the IndustryCitrin Cooperman
This presentation focused on what the future is likely to bring to manufacturers and distributors as the nation attempts to claw its way back from the worst of the COVID-19 crisis.
High Net Worth Webinar Series: SALT Thoughts - Pass-Through Entity Taxes & Re...Citrin Cooperman
During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
The New Rage in SALT: State Pass-Through Entity TaxCitrin Cooperman
During this webinar, Partner Eugene Ruvere and Principal Jaime Reichardt take deeper dive into the new elective tax regime in New York, in addition to neighboring states like Connecticut, New Jersey, and Rhode Island, among others.
C-Suite Snacks Webinar Series: What's Your IP Worth? Discovering the Value of...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Every day brings news of a new music catalog sale, strategic piece of intellectual property purchased by a large company or private equity firm, or major transaction of a patent-driven business.
During this C-Suite Snacks webinar session, we discussed which intangible assets and intellectual property are commanding the highest prices and what is behind the value of these assets. Key takeaways included:
- An overview of what drives IP value
- COVID-19 impacts on IP value
- Current IP value trends
C-Suite Snacks Webinar Series: Best-In-Class Finance and Accounting: Should Y...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
During this C-Suite Snacks webinar session, Jason Slivka, executive vice president of strategic initiatives, and Steve Ronan, principal and leader of our Business Process Outsourcing Practice, discussed how outsourcing your accounting function drives profitability and business value. They covered:
- Cleaning up historical books and records
- Combining in-house staff and outsourced capabilities
to get best-in-class expertise across your accounting
function
- How better forecasting and financial analysis drives
better management decisions
- Best practices for accounting technology
- Trends in middle-market accounting operations
C-Suite Snacks Webinar Series: Not Sold on Selling Your Business? Why Now is ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The recently proposed tax provisions in the Biden Administration’s American Families Plan should provide substantial incentives for business owners to discuss the creation of an Employee Stock Ownership Plan (ESOP).
During this C-Suite Snacks webinar session, Howard Klein and Heather Oboda covered more about ESOPs, including:
- An overview of what an ESOP is including financial and non-financial benefits
- The common misconceptions about ESOPs
- How the current tax proposals make an ESOP more attractive
MasterSnacks: Cybersecurity - Playing Offense: A Proactive Approach to Cybers...Citrin Cooperman
Sign up for our weekly MasterSnacks courses here: https://www.citrincooperman.com/infocus/mastersnacks
MasterSnacks, our C-Suite Snacks spin-off, brings you a series of topic-specific courses, using our snack-sized sessions to go in depth on content important to you. Join MasterSnacks live every Wednesday at noon for live exclusive sessions.
In today's world, a cyber attack happens every 39 seconds on average. For every doom and gloom story we can tell, there are also instances where another organization’s proactive defense has helped to avoid a cyber attack.
During our final MasterSnacks: Cybersecurity session, we discussed strategies your company can implement to move your IT environment from reactive to proactive. We also shared examples of current clients whose proactive positions have had a real impact in thwarting hackers' attempts at infiltrating their organizations. We covered:
- Case studies on companies that have successfully staved off cyber attacks
- Proactive strategies for protecting your infrastructure
- Automated tools to facilitate more timely evaluation and monitoring
MasterSnacks: Cybersecurity - Disaster Recovery: Hoping for the Best but Plan...Citrin Cooperman
Sign up for our weekly MasterSnacks courses here: https://www.citrincooperman.com/infocus/mastersnacks
MasterSnacks, our C-Suite Snacks spin-off, brings you a series of topic-specific courses, using our snack-sized sessions to go in depth on content important to you. Join MasterSnacks live every Wednesday at noon for live exclusive sessions.
Since a disaster is more a matter of “when” and not “if,” it’s critical to have a plan in place to ensure a rapid recovery. Whether it’s a natural cataclysm or a human-made catastrophe, having actionable, tested steps in place to recover could mean the difference between a brief outage and weeks of downtime.
During session 2, we covered disaster recovery planning. Key takeaways included:
- Knowing the key components to include in a plan
- Understanding Recovery Time Objective (RTO) and Recovery Point Objective (RPO)
- Differentiating between disaster recovery, business continuity, and incident response plans
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
Accpac to QuickBooks Conversion Navigating the Transition with Online Account...PaulBryant58
This article provides a comprehensive guide on how to
effectively manage the convert Accpac to QuickBooks , with a particular focus on utilizing online accounting services to streamline the process.
"𝑩𝑬𝑮𝑼𝑵 𝑾𝑰𝑻𝑯 𝑻𝑱 𝑰𝑺 𝑯𝑨𝑳𝑭 𝑫𝑶𝑵𝑬"
𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
𝐓𝐉 𝐂𝐨𝐦𝐬 provides unlimited package services including such as Event organizing, Event planning, Event production, Manpower, PR marketing, Design 2D/3D, VIP protocols, Interpreter agency, etc.
Sports events - Golf competitions/billiards competitions/company sports events: dynamic and challenging
⭐ 𝐅𝐞𝐚𝐭𝐮𝐫𝐞𝐝 𝐩𝐫𝐨𝐣𝐞𝐜𝐭𝐬:
➢ 2024 BAEKHYUN [Lonsdaleite] IN HO CHI MINH
➢ SUPER JUNIOR-L.S.S. THE SHOW : Th3ee Guys in HO CHI MINH
➢FreenBecky 1st Fan Meeting in Vietnam
➢CHILDREN ART EXHIBITION 2024: BEYOND BARRIERS
➢ WOW K-Music Festival 2023
➢ Winner [CROSS] Tour in HCM
➢ Super Show 9 in HCM with Super Junior
➢ HCMC - Gyeongsangbuk-do Culture and Tourism Festival
➢ Korean Vietnam Partnership - Fair with LG
➢ Korean President visits Samsung Electronics R&D Center
➢ Vietnam Food Expo with Lotte Wellfood
"𝐄𝐯𝐞𝐫𝐲 𝐞𝐯𝐞𝐧𝐭 𝐢𝐬 𝐚 𝐬𝐭𝐨𝐫𝐲, 𝐚 𝐬𝐩𝐞𝐜𝐢𝐚𝐥 𝐣𝐨𝐮𝐫𝐧𝐞𝐲. 𝐖𝐞 𝐚𝐥𝐰𝐚𝐲𝐬 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐬𝐡𝐨𝐫𝐭𝐥𝐲 𝐲𝐨𝐮 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐚 𝐩𝐚𝐫𝐭 𝐨𝐟 𝐨𝐮𝐫 𝐬𝐭𝐨𝐫𝐢𝐞𝐬."
Buy Verified PayPal Account | Buy Google 5 Star Reviewsusawebmarket
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2. 2
Disclaimer
Any U.S. tax advice contained in this communication (including
attachments) is not intended or written to be used, and cannot be used,
for the purpose of (I) avoiding penalties under the internal revenue code;
or (II) promotions, marketing or recommending to another party any
transactions or tax-related matters addressed herein.
If you have any questions, please contact 212.697.1000.
3. Today’s Presenters
3
F. Wayne Holton, CPA
International Tax Partner
Paul Dailey, CPA, MBA
International Tax Partner
Andrew Rotter, JD, CPA
International Tax Partner
Jeff Slavet, JD, CPA, LLM
International Tax Partner
5. 5
Chapter 4 Status
Chapter 4, sections 1471-1474 was added to the Internal Revenue Code in
2010 as part of the HIRE Act. Chapter 4 requires FFI’s to identity US account
holders and to report them to the IRS. Additionally, non FFI’s, known as non-
financial foreign entities (NFFE) are required to provide information related to
the identity of substantial US owners which are generally holders of greater
than 10% of the NFFE.
FFI’s and NFFE’s that do not comply with the requirements of chapter 4 will be
subjected to a 30% withholding tax on payments made to them of certain US
sourced FDAP, as well as beginning on January 1, 2017 gross proceeds from
the sale or other disposition of debt and equity instruments. FFI’s that are not
compliant will be deemed to be nonparticipating FFI’s.
Form W8-BENE has listed 31 different Chapter 4 status’ under
FATCA. Depending on the category that an entity falls under, that will
determine which sections of the form needs to be completed.
7. 7
FFI: Foreign Financial Institution
The definition of a FFI (Foreign Financial Institution) is one of the most critical threshold issues when analyzing the impact of FATCA
Must first be a foreign entity
Any entity that is not a U.S. person
Types of Financial Institutions
• Banks – Depository Institutions
• Custodial Institutions
• Investment entities
• Entities that conduct certain enumerated investment management activities on behalf of customers.
• Professionally managed entities exceeding gross income thresholds for certain activities. At least 50% during a
measurement period.
• Holding themselves out as collective investment vehicles or similar products.
• Insurance Companies
• Holding Companies or Treasury Centers
Exclusions
• Excepted nonfinancial group entities
• Excepted nonfinancial start-up companies
• Excepted nonfinancial entities in liquidation or bankruptcy
• Excepted inter-affiliated FFI’s
• Sec. 501(C) entities
• Nonprofit organizations
8. 8
Polling Question #1
A foreign entity that invests in a U.S. hedge fund and that pays a
management fee to an investment entity is a FFI.
True
False
10. 10
NFFE: Non-Foreign Financial Entity
30% withholding tax applies unless NFFE provides certification regarding Chapter 4 status and U.S. owners, if applicable.
EXCEPTED ENTITIES
• Excluded entities (see discussion re: FFI’s )
• Publicly Traded Company, including affiliates
• Active NFFE’s
50% (less than) gross income and asset measurement-TRADE or BUSINESS ACTIVITIES OTHER THAN
• Dividends
• Interest
• Equivalents
• Rents & Royalties (other than active conduct by employees)
• Annuities
• Sale or exchange of Passive Assets
• Futures, forward transactions, etc.
• Sec. 988 transactions
• Notional principal contracts
• Cash value insurance contracts
• Certain Insurance company income relating to its reserves
• Territory Entities
OTHERWISE
Will be classified as a passive NFFE
• Direct Reporting NFFE’s
11. 11
Polling Question # 2
A foreign entity that is engaged in an active trade or business outside of
the U.S. is not a NFFE.
True
False
13. 13
Common Terms 1
FATCA- The Foreign Account Tax Compliance Act, enacted as part of the HIRE act which added Chapter 4 to
the internal revenue code to enforce offshore account compliance.
Foreign Financial Institution (FFI)- A financial institution that is a non US entity. The regulations identify
basic types of financial institutions which include depository institutions (banks), custodial institutions (mutual
funds), investment entities (hedge funds and private equity funds), and certain insurance companies that have
cash value or annuity products.
Global Intermediary Identification Number (GIIN)- This is a number assigned to a participating FFI (PFFI),
registered deemed compliant FFI, direct reporting Non-Financial Foreign Entity (NFFE) to identify such
entities having been registered and approved to withholding agents and the IRS.
Non-Financial Foreign Entity (NFFE)- An entity organized outside the U.S. that is not a financial institution.
FDAP Income- Fixed or determinable, annual or period income. This includes interest, dividends, gross
proceeds (beginning 1/1/17) from the sales of property that can produce interest or dividends.
Expanded Affiliated Group (EAG)- Group of entities that are connected to each other through common
ownership. The FATCA status of members of the EAG can affect the FFI’s in the group to be FATCA
compliant.
Withholdable Payment- A payment subject to withholding under Chapter 4. Including payments of FDAP
income made after June 30, 2014 and the gross proceeds from the disposition of after December 31, 2016.
14. 14
Common Terms 2
Active NFFE — An NFFE that is treated as an excepted NFFE because it satisfies requirements that both its income and its assets are
predominantly active.
Certified deemed-compliant FFI — An FFI that is treated as complying with FATCA without being required to register with the IRS or
enter into an FFI agreement.
Deemed-compliant FFI — An FFI that is treated as FATCA compliant without being required to enter into an FFI agreement. Deemed-
compliant FFIs may be registered deemed-compliant FFIs (which are required to register with the IRS) or certified deemed-compliant
FFIs (which are not required to register with the IRS).
Limited FFI — An FFI that is in the same EAG as a PFFI and is located in a jurisdiction the laws of which do not permit it to comply with
the PFFI agreement (and that does not otherwise qualify as a deemed-compliant FFI or exempt beneficial owner). For a limited time, a
PFFI may have limited FFI affiliates if the PFFI follows certain procedures with respect to such limited FFI affiliates.
Owner-documented FFI — An investment entity FFI that, by virtue of satisfying certain requirements, is eligible to provide information
regarding its owners that are specified U.S. persons to certain designated withholding agents that then agree to report to the IRS (or to
anon-U.S. government under a Model 1 FFI) with respect to any specified U.S. persons identified.
Passive NFFE — An NFFE that does not satisfy the requirements of any of the categories of excepted NFFEs. When a passive NFFE
receives withholdable payments, it must certify either that (i) it has no substantial U.S. owners, or (ii) if it does have substantial U.S.
owners, identify each substantial U.S. owner.
Preexisting account — A financial account maintained by a financial institution that is outstanding on June 30, 2014. However, with
respect to entity accounts, a financial institution may treat an account outstanding on December 31, 2014 as a preexisting account.
16. 16
Payee Identification Procedures
In simple terms, the hallmark of the FATCA provisions is to attempt to identify U.S. investors/ owners
of foreign entities so as to minimize/ prevent tax evasion. Withholding agents must report ( both to the
payee and IRS), withhold, and deposit any withheld tax as required. Reporting entails the
identification of the payee and the character and source of payments.
Chapter 4, unlike chapters 3 and 61, imposes withholding on the payee whether or not the payee is
the beneficial owner of the income being paid. The payee is defined as the person to whom a payment
is made. The holder of a financial account is the payee if the payment is being made to a financial
account unless an exception applies. Relevant exceptions are as follows:
• Payments to Non-U.S. Agents and Intermediaries
• Payments to Non-U.S. Flow-Through Entities
• Payments to U.S. Intermediaries or Agents
• Payments to Disregarded Entities and Branches
After the determination of the payee, the withholding agent must obtain the appropriate documentation
or apply the presumption rules so as to determine the payee’s chapter 4 status. FATCA still relies on
Forms W-8 and W-9 as the primary form of documentation. FATCA, however, expands on the
permitted documents available for a payee to present to a withholding agent to document its status in
lieu of or in conjunction with Forms W-8 and W-9. Our professional advice, however, is that a properly
completed Form W-8 or W-9, is still the preferred form of documentation in almost all situations.
18. 18
IGA: Intergovernmental Agreement
These are bilateral agreements between the US Treasury Department and other
countries. These agreements were created to allow FFI’s to comply with section 4 and still be
in compliance with their local laws.
Model 1 IGA
• These require that an FFI that is organized in a FATCA partner country report information
regarding US accounts to the FFI’s own tax authorities which then forward such information
to the IRS.
• Reporting model 1 FFI’s are also required to register with the IRS. They are then
considered to be registered deemed compliant FFI’s.
Model 2 IGA
• These require that an FFI comply with Chapter 4, and to enter into an agreement directly
with the IRS and to report to the IRS with respect to their US accounts.
• Reporting model 2 FFI’s are considered to be participating FFI’s (PFFI). These entities are
then subject to extensive reporting to prevent offshore tax evasion by US account holders.
19. IGA Country Summary
19
Model 1 IGA Model 2 IGA
Australia (4-28-2014)
Belgium (4-23-2014)
Brazil (9-23-2014)
British Virgin Islands (6-30-2014)
Canada (2-5-2014)
Cayman Islands (11-29-2013)
Costa Rica (11-26-2013)
Czech Republic (8-4-14)
Denmark (11-19-2012)
Estonia (4-11-2014)
Finland (3-5-2014)
France (11-14-2013)
Germany (5-31-2013)
Gibraltar (5-8-2014)
Guernsey (12-13-2013)
Hungary (2-4-2014)
Honduras (3-31-2014)
Ireland (1-23-2013)
Isle of Man (12-13-2013)
Israel (6-30-2014)
Italy (1-10-2014)
Jamaica (5-1-2014)
Jersey (12-13-2013)
Latvia (6-27-2014)
Liechtenstein (5-19-2014)
Lithuania (8-26-2014)
Luxembourg (3-28-2014)
Malta (12-16-2013)
Mauritius (12-27-2013)
Mexico (4-9-2014)
Netherlands (12-18-2013)
New Zealand (6-12-2014)
Norway (4-15-2013)
South Africa (6-9-2014)
Spain (5-14-2013)
Slovenia (6-2-2014)
Sweden (8-8-2014)
United Kingdom (9-12-2012)
Austria (4-29-2014)
Bermuda (12-19-2013)
Chile (3-5-2014)
Japan (6-11-2013)
Switzerland (2-14-2013)*
*Note: Switzerland is
currently a Model 2 IGA,
but is set to become a
Model 1 IGA.
20. Jurisdictions with Agreements in Substance
20
Model 1 IGA Model 2 IGA
Algeria (6-30-2014)
Anguilla (6-30-2014)
Antigua & Barbuda (6-3-
2014)
Azerbaijan (5-16-2014)
Bahamas (4-17-2014)
Bahrain (6-30-2014)
Barbados (5-27-2014)
Belarus (6-6-2014)
Bulgaria (4-23-2014)
Cabo Verde (6-30-2014)
China (6-26-2014)
Colombia (4-23-2014)
Croatia (4-2-2014)
Curaçao (4-30-2014)
Cyprus (4-22-2014)
Dominica (6-19-2014)
Dominican Republic (6-30-
2014)
Georgia (6-12-2014)
Greenland (6-29-2014)
Grenada (6-16-2014)
Guyana (6-24-2014)
Haiti (6-30-2014)
India (4-11-2014)
Indonesia (5-4-2014)
Kosovo (4-2-2014)
Kuwait (5-1-2014)
Malaysia (6-30-2014)
Montenegro (6-30-2014)
Panama (5-1-2014)
Peru (5-1-2014)
Poland (4-2-2014)
Portugal (4-2-2014)
Qatar (4-2-2014)
Romania (4-2-2014
St. Kitts and Nevis (6-4-
2014)
St. Lucia (6-12-2014)
St. Vincent and the
Grenadines (6-2-2014)
Saudi Arabia (6-24-2014)
Serbia (6-30-2014)
Seychelles (5-28-2014)
Singapore (5-5-2014)
Slovak Republic (4-11-2014)
South Korea (4-2-2014)
Thailand (6-24-2014)
Turkey (6-3-2014)
Turkmenistan (6-3-2014)
Turks and Caicos Islands (5-
12-2014)
Ukraine (6-26-2014)
United Arab Emirates (5-21-
2014)
Uzbekistan (6-30-2014)
Armenia (5-8-2014)
Hong Kong (5-9-2014)
Iraq (6-30-2014)
Nicaragua (6-30-2014)
Moldova (6-30-2014)
Paraguay (6-6-2014)
San Marino (6-30-2014)
Taiwan (6-23-2014)*
22. 22
What is a GIIN
GIIN is a Global Intermediary Identification Number. These numbers are
assigned to participating FFI’s (PFFI) and registered deemed compliant FFI’s.
Each GIIN assigned is a 19 digit character that is composed of
multiple identifiers.
The first 6 digits are a randomly generated alpha numeric
string. They are all upper case letters, excluding the letter “O” and numbers or
a combination of both. (See composition ledger as prepared by the treasury
department).
FATCA and GIIN registration should be done on the following
website: www.irs.gov/fatca-registration.
For additional information there is a FATCA user guide available at
www.irs.gov/pub/irs-pdf/p5118.pdf.
23. 23
Character Representation # of Char. Position Description/ Rules
XXXXXX
FATCA ID (first six characters)
6 1-6 Alphanumeric upper case only.
For all Financial Institutions, this is the same as the first 6
characters of the FATCA ID. For leads and singles, this is your
FATCA ID, for members, this is just the first six characters.
(First 6 characters of any Financial Institution’s FATCA ID are
randomly generated and will never use the letter “O”)
Separator 1 1 7 Period = .
XXXXX
Financial Institution Type
5 8-12 Alphanumeric upper case only.
Lead = 00000; Sponsoring Entity = 00000; Single = 99999
Member = Same as the last 5 characters of the Member’s
FATCA ID (sequential, starting from 00001 and going to 99998,
then A0000- ZZZZZ; will never use the letter “O”)
Separator 2 1 13 Period = .
XX
Category Code
2 14-15 Alpha upper case only.
Based on Financial Institution or Branch Category
LE = Lead; SL = Single; ME = Member; SP = Sponsoring Entity;
BR = Branch (the first 13 characters of a branch’s GIIN will
match the first 13 characters of the GIIN of the Financial
Institution with which the branch is associated)
Separator 3 1 16 Period = .
XXX
Country Identifier
3 17-19 Numeric.
ISO 3166-1 numeric standard country code of the Financial
Institution or Branch
NOTE: Use 999 for country code “Other”
25. 25
Treaty Benefits
Traditionally, a Form W-8 BEN was utilized by foreign persons to claim treaty
benefits. With the onslaught of the new FATCA provisions, one must not forget,
however, that such is still the case.
A withholding agent may rely on a properly completed Form W-8 BEN-E to apply a
reduced rate of, or exemption from withholding pursuant to applicable treaty
provisions. If the payee receives certain types of income, they must provide Form
W-8BEN-E to:
• Claim that they are the beneficial owner of the income AND
• If applicable, claim a reduced rate of, or exemption from withholding as a
resident of a foreign country with which the U.S. has an income treaty that is
eligible for treaty benefits.
Other than for dividends and interest from stocks and debt obligations that are
actively traded, the foreign payee should complete Part I, Line 9b Foreign TIN.
Part II should be completed in such context. Special attention must be paid to any
Limitations of Benefits Article ( Line 14b ).
26. 26
Polling Question #3
If the payee receives certain types of income, they must provide Form W-
8BEN-E to:
Claim that they are the beneficial owner of the income
Claim a reduced rate or exemption from withholding
All of the Above
28. 28
FATCA Essentials for the Future
DDPPI
Documentation
Diligence
Policies
Procedures
Implementation
Completion of Forms including W-8BEN-E
Expiration- Generally, will remain valid for a period of three years
• Indefinite validity , however, unless there is a change of circumstances,
See Reg. Sec.1.1471-3(c) (6)(ii)
– Provided by a participating FFI or registered deemed –compliant
FFI that has furnished a valid GIIN
– Provided by an individual that has furnished documentary evidence
supporting claim of foreign status
Registration
FATCA Timeline
29. FATCA Reporting Timeline
29
Year When to Report Who Should Report What to Report
2015 March 31 FFIs in non-IGA jurisdictions and
FFIs in Model 2 IGA jurisdictions
With respect to 2014:
1. Account holder’s name. For passive non-financial foreign entity, the
name(s) of any substantial U.S. owners.
2. Account holder’s U.S. taxpayer identification number (TIN). For
passive non-financial foreign entity, only the TIN(s) of any substantial
U.S. owner(s).
3. Account holder’s address. For passive non-financial foreign entity, only
the address(es) of substantial U.S. owner(s).
4. Account number.
5. Account balance or value.
6. For accounts held by recalcitrant/ non-consenting account holders:
report aggregate number and balance or value.
September 30 FFIs in Model 1 IGA jurisdictions
2016 March 31 FFIs in non-IGA jurisdictions and
FFIs in Model 2 IGA jurisdictions
With respect to 2015:
1-6. (See above)
7. Income paid (except certain gross proceeds from the sale or
redemption of property).September 30 FFIs in Model 1 IGA jurisdictions
2017 March 31 FFIs in non-IGA jurisdictions and
FFIs in Model 2 IGA jurisdictions
With respect to 2016:
1-7. (See above)
8. Gross proceeds paid to custodial accounts.
September 30 FFIs in Model 1 IGA jurisdictions
After
2017
March 31 FFIs in non-IGA jurisdictions and
FFIs
With respect to previous year:
1-8. (See above)
September 30 FFIs in Model 1 IGA jurisdictions
30. Today’s Presenters
30
F. Wayne Holton, CPA
International Tax Partner
fholton@citrincooperman.com
Paul Dailey, CPA, MBA
International Tax Partner
pdailey@citrincooperman.com
Andrew Rotter, JD, CPA
International Tax Partner
arotter@citrincooperman.com
Jeff Slavet, JD, CPA, LLM
International Tax Partner
jslavet@citrincooperman.com
31. CONNECTICUT | NEW JERSEY | NEW YORK | PENNSYLVANIA
Thank you for attending.
Visit us online at:
citrincooperman.com
@CitrinCooperman
212.697.1000