October 15, 2012: Sutherland
FATCA comment letter
Sutherland follows up on the application of the Foreign Account Tax Compliance Act (FATCA) rules to certain non-US insurance and reinsurance companies that will not be considered foreign financial institutions (FFIs) under section 1471 of the code and the proposed regulations there under. As non-FFIs, the entities will constitute "non-financial foreign entities" (NFFEs) under section 1472 of the Code.
A copy of the comment letter, submitted to the IRS in response to FATCA can be downloaded. Contact FATCA leaders for further information.