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Three-part FATCA Article Written by Dean Marsan Originally Published in Taxes – The Tax Magazine


Dean Marsan’s three-part series titled “FATCA: The global financial system must now implement a new U.S. reporting and withholding system for foreign account tax compliance which will create significant new exposures – Managing this risk,” have appeared in the July, August, and September 2010 issues of Taxes — The Tax Magazine.

This article is separated into a three-part series. The article addresses the new reporting and withholding regime imposed upon foreign financial institutions and nonfinancial foreign entities, its impact on banks, insurance companies, multinational corporations and investment and mutual funds, as well the new reporting requirements for uncertain tax positions for U.S. and foreign corporations including life, property and casualty insurance companies and new tax compliance for individuals with foreign assets. In addition, the article discusses changes to the tax treatment of substitute dividends and dividend equivalent payments received by foreign persons, the repeal of certain foreign exceptions to the registered bond provisions, IRS U.S. withholding tax and information reporting examinations, liabilities for U.S. withholding tax, interest and penalties, U.S. account exposures, prophylactic planning and action steps, corporate governance and compliance to manage the U.S. account risk.

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