On April 8th, the IRS unveiled its much-anticipated second notice on the Foreign Account Tax Compliance Act ("FATCA"). The new guidance provides additional clarity on how banks identify U.S. accounts, as well as new guidance on the treatment of passthru payments, but many questions are still left unanswered. In this white paper, the second in a series by Ellen Zimiles, Richard Kando and Jeff Locke, we review the new Notice and discuss practical steps that financial institutions can take now to prepare for FATCA.
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