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August 16, 2010: American Bar Association Section of Taxation (ABA)


The American Bar Association Section of Taxation (ABA) submitted in-depth comments to the Internal Revenue Service (IRS) asking for further clarification and guidance to the requirements under FATCA.

The ABA tax section estimated that there are hundreds of thousands of financial institutions that would currently be required to enter into agreements with the IRS. Among other exclusions of who would be exempt from the FATCA reporting requirements, they have asked for carve-outs for certain types of insurance companies, certain UCITS, and collective investment vehicles targeted to foreign investors and U.S. tax-exempt investors.  ABA requested further definition or clarification of terms such as “withholdable payment”, “passthru payments”, and “gross proceeds”.

Download the attached comment letter.

Contact FATCA Leader for further information.

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