ELIZABETH A. McMORROW LAW LLC

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Elizabeth A. McMorrow

Apr 17, 2018

FATCA: Head’s Up 3301 Registered Singapore FIs

Singapore released its FATCA reporting nil paper form yesterday. The Inland Revenue Authority of Singapore (IRAS) requires nil reporting under FATCA. IRAS does not provide an online service or separate portal for manual input and reporting of FATCA data. Nil reporting can be accomplished through a paper form rather than through a complex electronic reporting process. 3301 Singapore Financial Institutions (FIs) have received Global Intermediary Identification Numbers (GIINs)

Elizabeth A. McMorrow

Apr 14, 2017

FATCA: Indian Financial Institutions Permitted to Block Accounts

India’s Central Board of Direct Taxes (CBDT) issued an update regarding the US-India FATCA IGA. India and the USA entered into a Model 1 IGA for implementation of FATCA on 31st August, 2015. As part of the IGA implementation, India’s income tax rules included an alternate procedure for due diligence (Rule 114H(8)). If the financial institution determined that the self-certification was unacceptable and the account holder failed to cure the defect by 31 August 2016, then the f

Elizabeth A. McMorrow

Oct 28, 2016

IRS Pushes Out Date to Use New W-8BEN-E

In April 2016, the IRS released a new Form W-8BEN-E. Ordinarily, the old 2014 Form W-8BEN-E would be permitted to be used for six months subsequent to the release of the new form. Thus, the mandatory date to use the April 2016 form would be November 1, 2016. The IRS issued an update to the IRS Form W-8BEN-E instructions providing that a withholding agent may accept, and may request that a client provide, the February 2014 revision of Form W-8BEN-E until January 1, 2017. Th

Elizabeth A. McMorrow

Sep 13, 2016

Mandatory Use of 2016 Form W-8BEN-E Coming Down the Pike

In April 2016, the IRS released a new Form W-8BEN-E. The old 2014 Form W-8BEN-E is permitted to be used for six months subsequent to the release of the new form. The mandatory date to use the 2016 form is creeping up on us as November 1, 2016 approaches. For a Form W-8BEN-E, the validity period is generally the period starting on the date the form is signed and ending on the last day of the third succeeding calendar year absent a change in circumstances. For example, a For

Elizabeth A. McMorrow

Sep 1, 2016

India Prohibits FATCA Account Closures

India and the USA entered into a Model 1 IGA for implementation of FATCA on 31st August, 2015. As part of the IGA implementation, India’s income tax rules included an alternate procedure for due diligence (Rule 114H(8)). This rule required financial institutions to obtain self-certifications from account holders who had opened new accounts as of 1 July 2014. The due diligence process also included a requirement that the financial institution determine the reasonableness of t