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Final major regulations package for FATCA

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The IRS has issued the last substantial package of regulations necessary to implement FATCA. Key amendments include those relating to the accommodation of direct reporting to the IRS, rather than to withholding agents, by certain entities regarding their substantial US owners, the treatment of certain special-purpose debt securitisation vehicles, the treatment of disregarded entities as branches of foreign financial institutions, the definition of ‘expanded affiliated group’ and transitional rules for collateral arrangements prior to 2017. The new guidance also harmonises the requirements contained in pre-FATCA reporting and withholding rules in order to integrate these rules and reduce burdens – including certain duplicative information reporting obligations.

HMRC has published updated guidance notes on FATCA. These guidance notes will need to be updated again following the publication of the last set of regulations by the IRS.