Regulatory Analysis

Posted June 30, 2017 by Tom Hospod
IRS Reminds Financial Institutions to Renew FFI Agreements

The IRS released an updated FFI Agreement for Financial Institutions with FATCA obligations on December 30, 2016. Those FFIs whose agreements expired at the end of last year, and that wish to retain their GIINs, are required to renew their FFI Agreements. They can do so through the FATCA FFI Registration System. The FFIs will be […]

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Posted June 30, 2017 by Tom Hospod
IRS Releases Drafts of Form W-8IMY and Instructions

The IRS has published draft versions of its revised Form W-8IMY, Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding and Reporting, and instructions for filers of this form. There are a number of significant updates to this form of which filers should be aware: Qualified […]

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Posted June 29, 2017 by Paul Ogawa
South Carolina Releases Updated Interest Rates for Overpayments and Underpayments

The South Carolina Department of Revenue recently published Information Letter #17-9, detailing interest rates for overpayments and underpayments relating to withholding tax through September 2017. South Carolina publishes these Information Letters periodically throughout the year, and these letters are the primary method of notifying the taxpaying public about changes in withholding tax interest. The […]

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Posted June 29, 2017 by Paul Ogawa
South Carolina Releases Updated Withholding Tax Coupon

South Carolina recently released an updated Form WH-1601, Withholding Tax Coupon. This form/coupon is used to submit payment to the South Carolina Department of Revenue. This form/coupon also has an electronic counterpart on the South Carolina MYDORWAY online portal for those who make their payments electronically. There was one minor change to the preliminary […]

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Posted June 29, 2017 by Jesse Rooney
Virginia Releases Updated Electronic Payment Guide

Virginia has lately released an updated copy of its Electronic Payment Guide.  This guide details the instructions necessary to complete an ACH payment to the Department of Taxation.  No material changes were made to instructions for filing or paying taxes related to withholding or information returns.  Some changes were made to the instructions for […]

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Posted June 28, 2017 by Tom Hospod
Senate Delays Vote on Health Care Bill until after July 4th Recess

Senate Majority Leader Mitch McConnell announced Tuesday afternoon that the Senate would not hold a vote this week on the Better Care Reconciliation Act of 2017, as had been originally planned. Senate leadership cited a need for further revision to the original draft, as five Senators have vowed to vote against the bill in its current form. A […]

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Posted June 27, 2017 by Tom Hospod
CBO Scores Senate Healthcare Bill–22 Million Additional Uninsured

The Congressional Budget Office has handed down its report on last week’s discussion draft of the Senate’s Better Care Reconciliation Act of 2017. By the CBO’s estimate, the Senate bill would result in an additional 22 million Americans being uninsured over the next 10 years – on top of the current estimated 28 million who […]

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Posted June 26, 2017 by Tom Hospod
Croatia Publishes New CRS Technical Instructions and Reporting Information

The Croatian Tax Administration has published a final draft of its CRS Schema Guide and Technical Specifications. The specifications for several of the data elements and attributes in the XML have been modified since the prior publication. Additionally, the schema guide now contains a table of validation rules that the XML files must meet in […]

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Posted June 26, 2017 by Tom Hospod
Gibraltar Publishes CRS Guidance and Reportable Jurisdictions

The Gibraltar Competent Authority has published its list of CRS reportable jurisdictions, as well as some specific guidance related to reporting obligations, due diligence, debt interest, the transition from CDOT, and the XML schema. Gibraltar currently has agreements to exchange information with 20 countries – 13 of which are early adopters and will commence […]

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Posted June 26, 2017 by Paul Ogawa
Netherlands Publishes Reminder of AEOI Reporting Due Date

The Netherlands Competent Authority, through their Community Data Partners website, published a reminder for all FIs submitting FATCA and/or CRS data in 2017. All submissions must be made by August 1, 2017: any initial file deliveries or corrections received after that date may not be considered. To review this published notice, please visit the […]

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Posted June 26, 2017 by Tom Hospod
Hong Kong Expands List of Reportable Jurisdictions to 75 Countries

The Legislative Council of Hong Kong has passed a bill that adds 73 countries to its list of CRS Reportable Jurisdictions, bringing the total number to 75 jurisdictions. In enacting this bill, Hong Kong is committing to automatic exchanges of account information with each of its preexisting tax treaty partners that has signed the Multilateral […]

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Posted June 23, 2017 by Tom Hospod
Senate Drafts ACA Replacement Bill, Does Not Repeal Employer Reporting

Senate leadership released a discussion draft of the Better Care Reconciliation Act of 2017 – its version of the House’s American Health Care Act (AHCA) intended to repeal and replace the Affordable Care Act. Although this legislation would nullify penalties for the individual and employer mandates, it would not repeal IRS reporting obligations under […]

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Posted June 21, 2017 by Tom Hospod
Bermuda Launches Tax Information Reporting Portal with Guidance and Enrollment Deadline

Bermuda’s Ministry of Finance has launched its Tax Information Reporting Portal, through which Financial Institutions and filers may enroll in and exchange account information pursuant to the Common Reporting Standard (CRS). The Ministry has also published a User Guide for navigating the Portal. It provides an overview of commonly used functionalities within the Portal […]

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Posted June 21, 2017 by Tom Hospod
Senate Leadership Aims for AHCA Vote Next Week; Working Group Expresses Unease

Senate Majority Leader Mitch McConnell has announced that leadership plans to release a “discussion draft” of their version of the AHCA bill on Thursday June 22^nd^, with a vote to be held on a final bill one week later. The Congressional Budget Office is expected to release a report concerning the Senate bill early next […]

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Posted June 20, 2017 by Tom Hospod
Germany Publishes FATCA Infobrief for Start of Filing Season

The German BZSt (Tax Office) has published an Infobrief to address some final matters before the start of this year’s FATCA filing season. The BZSt online portal will be available for FATCA transmittals beginning on June 19. Both mass data interface (ELMA) and manual data entry will be operational from this date forward. However, […]

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Posted June 19, 2017 by Paul Ogawa
California Publishes Updated Electronic Funds Transfer Bulk Filer Setup Guide

California recently released an updated version of Publication DE-154, Electronic Funds Transfer Bulk Filer Setup Guide. The purpose of this guide is to provide instruction for payroll agents who use the ACH Debit method to electronically pay the Payroll Tax Deposit using Form DE-88. This publication also provides detailed information on formatting files to submit […]

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Posted June 19, 2017 by Charles Riordan
Council Fails to Reach Agreement on European Union VAT Proposals

Two proposals to transform European VAT law have failed to gain approval of the EU’s Economic and Financial Affairs Council (ECOFIN). Both proposals needed unanimous approval of the delegates to become law. ECOFIN began its meeting of June 16 by debating a proposal that would allow Member States to apply reduced VAT rates to electronic […]

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Posted June 15, 2017 by Paul Ogawa
Turks and Caicos Publishes List of Reportable Jurisdictions for 2017

The Ministry of Finance, Trade, and Investment in Turks & Caicos recently published a list of Reportable Jurisdictions for 2017. These jurisdictions have an existing agreement in place with Turks & Caicos to exchange tax information under CRS. Please note that while this list is currently up to date, it is subject to change […]

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