Foreign Account Tax Compliance Act (FATCA) Comment Letter to IRS and Responses |
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The below comment letters were submitted to the Internal Revenue Service (IRS) regarding Foreign Account Tax Compliance Act (FATCA). Any responses from the IRS or other government agency are posted as well. Comments and responses are posted as soon as they are made public. Tell us about a new comment submission by contacting us at FATCA@deloitte.com.
April 30, 2012: Asset Based Finance Association (ABFA)
Asset Based Finance Association (ABFA) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: Association of British Insurers (ABI)
Association of British Insurers (ABI) submits comments to the Foreign Account Tax Compliance Act (FATCA) - Proposed Treasury Regulations §1.1471 - §1.1474.
April 30, 2012: Association of Private Client Investment Managers and Stockbrokers (APCIMS)
Association of Private Client Investment Managers and Stockbrokers (APCIMS) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: Credit Union National Association (CUNA)
Credit Union National Association (CUNA) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: European Banking Federation (EBF) and Institute of International Bankers (IIB)
European Banking Federation (EBF) and Institute of International Bankers (IIB) submit comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: Florida Bar Tax Section
Florida Bar Tax Section submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: Investment & Life Assurance Group (ILAG)
Investment & Life Assurance Group (ILAG) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: Swiss Reinsurance Corporation Ltd. and Subsidiaries (SwissRe)
Swiss Reinsurance Corporation Ltd. and Subsidiaries (SwissRe) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: Tax Executives Institute, Inc. (TEI)
Tax Executives Institute, Inc. (TEI) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 30, 2012: World Council of Credit Unions (World Council)
World Council of Credit Unions (World Council) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 29, 2012: International Bonnard Son Law Firm
International Bonnard Son Law Firm submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 27, 2012: Arbejdsmarkedets Tillaegspension (ATP) Labour Market Supplementary Pension (ATP) in Denmark
Arbejdsmarkedets Tillaegspension (ATP) Labour Market Supplementary Pension (ATP) in Denmark submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 27, 2012: Allianz S.E.
Allianz S.E. submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 27, 2012: Association of Financial Mutuals (AFM)
Association of Financial Mutuals (AFM) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 27, 2012: Federation of Brazilian Banks (FEBRABAN)
Federation of Brazilian Banks (FEBRABAN) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 26, 2012: Assuralia, the Belgian Insurance Association
Assuralia, the Belgian Insurance Association submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 25, 2012: International Tax Planning Committee of the Real Property Trust and Estate Law Section of the American Bar Association
International Tax Planning Committee of the Real Property Trust and Estate Law Section (the “RPTE Section”) of the American Bar Association (the “ABA”) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 23, 2012: American Council of Life Insurers (ACLI)
American Council of Life Insurers (ACLI) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 23, 2012: Division Bank and Insurance of the Austrian Federal Economic Chamber
The Division Bank and Insurance of the Austrian Federal Economic Chamber representing the entire Austrian banking industry submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 20, 2012: Barclays Bank PLC (Barclays)
Barclays Bank PLC (Barclays) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 20, 2012: Swiss Bankers Association (SBA)
Swiss Bankers Association (SBA) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 4, 2012: American Citizens Abroad (ACA)
American Citizens Abroad (ACA) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
April 4, 2012: Securities Industry and Financial Markets Association (SIFMA)
Securities Industry and Financial Markets Association (SIFMA) submits comments to the February 8, 2012 released proposed regulations on the Foreign Account Tax Compliance Act (FATCA) by the U.S. Treasury Department and the Internal Revenue Service (IRS).
March 13, 2012: Treasury Response to Congresswoman Maloney
The Assistant Secretary (Tax Policy) of the United States Treasury responds to Congresswoman Maloney’s comments about the impact on U.S. citizens’ resident abroad of the USA PATRIOT Act and the tax reporting provisions commonly known as FATCA.
February 9, 2012: Congresswoman Maloney
Congresswoman Carolyn Maloney's letter to Secretary of the Treasury Timothy Geithner with concerns with the implementation of the USA PATRIOT ACT and the impending implementation of Foreign Account Tax Compliance Act.
January 25, 2012: Institute of International Finance (IIF)
IIF comments on the serious concerns raised by FATCA, which was enacted by the U.S. in 2010.
January 18, 2012: Abu Dhabi Investment Council
Abu Dhabi Investment Council submits comments on the application of the Foreign Account Tax Compliance Act to sovereign wealth funds.
January 12, 2012: New York State Bar Association (NYSBA) Tax Section
The New York State Bar Association (NYSBA) submits NYSBA Tax Section report on Internal Revenue Service (IRS) Notice 2011-34 and IRS Notice 2011-53.
January 11, 2012: Congressman Levin on behalf Permanent Subcommittee on Investigations
Senator Carl Levin comments to Internal Revenue Service Notice 2011-34 on behalf of the Permanent Subcommittee of Investigations.
January 6, 2012: European Private Equity and Venture Capital Association (EVCA)
European Private Equity and Venture Capital Association’s (EVCA) Industry Response to Internal Revenue Service Notices 2010-60, 2011-34, 2011-53 and 2011-55 in respect of the Foreign Account Tax Compliance Act Provisions incorporated in Chapter 4 of the Hiring Incentives to Restore Employment Act.
December 28, 2011: The Chilean Association of Pension Fund Administrators (AFP)
The Chilean Association of Pension Fund Administrators (AFP) comments on Internal Revenue Service Notices 2010-60, 2011-34 and 2011-53 regarding the regulations to implement the Foreign Account Tax Compliance Act Provisions.
December 23, 2011: Ontario Teachers' Pension Plan Board (OTPPB)
Ontario Teachers' Pension Plan Board (OTPPB) expresses concerns regarding the potential application of the Foreign Account Tax Compliance Act provisions, as detailed in the Hiring Incentives to Restore Employment Act.
December 22, 2011: The Brazilian Federation of Banks (FEBRABAN)
FEBRABAN provides comments and suggestions on the Foreign Account Tax Compliance Act (FATCA) to the U.S. Department of Treasury and Internal Revenue Service (IRS).
December 14, 2011: European Federation of Building Societies (EFBS)
European Federation of Building Societies (EFBS) expresses concerns regarding the forthcoming application of the Foreign Account Tax Compliance Act in Europe.
December 14, 2011: Investment Industry Association of Canada (IIAC)
Implications of the Foreign Account Tax Compliance Act (FATCA) on the Capital Markets Business Sector.
December 7, 2011: British Private Equity and Venture Capital Association (BVCA)
British Private Equity and Venture Capital Association (BVCA) Industry Response to Internal Revenue Service Notices 2010-60, 2011-34, 2011-53 and 2011-55 in respect of the Foreign Account Tax Compliance Act Provisions.
December 2, 2011: Treasury Response to Representative Boustany
The Assistant Secretary (Tax Policy) of the United States Treasury responds to Representative Charles Boustany regarding proposed Treasury regulations.
November 30, 2011: The Real Estate Roundtable
The Real Estate Roundtable provides comments to the U.S. Treasury Department and Internal Revenue Service regarding FATCA.
November 23, 2011: Investment Industry Association of Canada (IIAC)
IIAC makes an urgent request for discussion of the implications of the Foreign Account Tax Compliance Act on the capital markets business sector.
October 28, 2011: Japanese Bankers Association (JBA)
The Japanese Bankers Association sends follow up comments to Notice 2011-34.
October 27, 2011: Commerzbank AG
Commerzbank submits comments regarding guidance to be issued by the Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS").
October 17, 2011: TryghedsGruppen smba
TryghedsGruppen submits comments on FATCA (new chapter 4) and to the Internal Revenue Code.
October 13, 2011: The Northern Trust Corporation (Northern Trust)
The Northern Trust Corporation (Northern Trust) asks to submit comments regarding Section 501.
October 05, 2011: German Banking Industry Committee (Die Deutsche Kreditwirtschaft)
German Banking Industry Committee highlight areas in the Foreign Account Tax Compliance Act (FATCA) regulations in which action is especially essential.
October 3, 2011: U.S. Treasury response to Sep 22, 2011 letter from Congressmen: Luetkemeyer, Paul, Campbell, and Manzullo
The letter urges to keep potential impact on U.S. capital markets in mind as U.S. House of Representatives implement the provisions of FATCA.
October 3, 2011: The Securities Industry and Financial Markets Association (SIFMA)
The Securities Industry and Financial Markets Association (SIFMA) submits follow-up comments on Foreign Account Tax Compliance Act (“FATCA”) including transition rules and related matters, passthrough payments, securitization vehicles, short-term debt and other technical comments.
September 23, 2011: Hogan Lovells US LLP
Hogan Lovells submits comments to Notice 2011-34.
September 22, 2011: Members of Congress, Blaine Luetkemeyer, Ron Paul, John Campbell, and Donald Manzullo
On September 22, Members of Congress, Blaine Luetkemeyer, Ron Paul, John Campbell, and Donald Manzullo, submitted a comment letter to U.S. Treasury Secretary, Timothy F. Geithner.
September 21, 2011: Association of Pension Lawyers (APL)
The UK’s APL comments on FATCA’s effect on UK pension provisions.
September 21, 2011: Tax Executive Institute (TEI)
Tax Executive Institute (TEI) submits follow-up comments on Notices 2010-60 and 2011-34 after meeting with U. S. Treasury Department and Internal Revenue Service on August 16, 2011.
August 31, 2011: American Citizens Abroad (ACA)
ACA Call for Repeal of FATCA Legislation.
August 30, 2011: The Hartford Financial Services Group, Inc.
The Hartford Financial Services Group, Inc. submits comments in response to Notice 2011-34 - Supplemental notice to Notice 2010-60
August 5, 2011: Treasury Assistant Secretary (Tax Policy) Responds to U.S. House of Representatives on Issue of Tax Policy
On August 5, Acting Assistant Secretary (Tax Policy) responded to the letters of Members of the U.S. House of Representatives, Francisco Canseco, Ruben Hinojosa, and Silvestre Reyes.
July 25, 2011: American Benefits Council (ABC)
ABC submits comments in response to Notices 2010-60, 2011-34 and 2011-53.
July 22, 2011: American Council of Life Insurers (ACLI)
ACLI submits comments in response to Notice 2011-34.
July 21, 2011: Royal Bank of Canada (RBC)
RBC submits comments in response to Notice 2011-34.
July 18, 2011: Center for Freedom & Prosperity (CF&P)
CF&P submits letters to Treasury and Congress Call for Cost-Benefit Analysis, Repeal of FATCA.
July 18, 2011: French Insurance Association (FFSA)
FFSA submits comments in response to Notice 2011-34.
June 28, 2011: International Council of Securities Associations (ICSA)
ICSA submits initial comments on implications of the Foreign Account Tax Compliance Act.
June 16, 2011: The Securities Industry And Financial Markets Association (SIFMA)
he Securities Industry and Financial Markets Association (SIFMA) responds to a question posed to SIFMA President & CEO Tim Ryan at a House Financial Services Committee hearing, regarding the “International Context of Financial Regulatory Reform.”
June 13, 2011: Association of the Bar of the City of New York Committee on Estate and Gift Taxation
Estate and Gift Taxation Committee of the Association of the Bar of the City of New York, submits comments on certain FATCA provisions as they relate to trusts and beneficiaries of trusts.
June 13, 2011: European Banking Federation (EBF)
EBF submits comments in response to Notice 2011-34.
June 13, 2011: The Association of the Bar of the City of New York
The Association of the Bar of the City of New York submits comments in response to Notice 2011-34.
June 10, 2011: Swiss Bankers Association (SBA)
SBA submits comments in response to Notice 2011-34.
June 9, 2011: Dutch Banking Association
Dutch Banking Association submits comments in response to Notice 2011-34.
June 7, 2011: Association of British Insurers (ABI)
ABI's response on Notice 2011-34 regarding the FATCA provisions incorporated into the Hiring Incentives to Restore Employment Act.
June 7, 2011: Association Française de la Gestion Financière (AFG)
AFG submits comments in response to Notice 2011-34.
June 7, 2011: Association of Investment Companies (AIC)
AIC submits comments in response to Notice 2011-34.
June 7, 2011: Austrian Association of Investment Management Companies (VOlG)
VOIG submits comments in response to Notice 2011-34.
June 7, 2011: Australia and New Zealand Banking Group Limited (ANZ)
ANZ submits comments in response to Notice 2011-34.
June 7, 2011: Australian Bankers' Association Inc. (ABA)
ABA submits comments in response to Notice 2011-34.
June 7, 2011: Aviva plc (AVIVA)
AVIVA submits comments in response to Notice 2011-34.
June 7, 2011: British Bankers’ Association (BBA)
BBA submits comments in response to Notice 2011-34.
June 7, 2011: Bundesverband Investment und Asset Management (BVI)
BVI submits comments in response to Notice 2011-34.
June 7, 2011: Canadian Bankers Association (CBA)
CBA submits comments in response to Notice 2011-34.
June 7, 2011: Euroclear SA/NV
Euroclear submits comments in response to Notice 2011-34.
June 7, 2011: European Fund and Asset Management Association (EFAMA)
EFAMA submits comments in response to Notice 2011-34.
June 7, 2011: Florida Bar Tax Section
The Florida Bar Tax Section submits comments in response to Notice 2011-34.
June 7, 2011: Financial Services Council (FSC)
FSC submits comments in response to Notice 2011-34.
June 7, 2011: General Insurance Association of Japan (GIAJ)
GIAJ submits comments in response to Notice 2011-34.
June 7, 2011: German Insurance Association (GDV)
GDV submits comments in response to Notice 2011-34.
June 7, 2011: HSBC Holdings plc (HSBC)
HSBC submits comments in response to Notice 2011-34.
June 7, 2011: Hunton & Williams
Hunton & Williams submits comments in response to Notice 2011-34.
June 7, 2011: Ignis Asset Management
Ignis Asset Management submits comments in response to Notice 2011-34.
June 7, 2011: Investment and Life Assurance Group (ILAG)
ILAG submits comments in response to Notice 2011-34.
June 7, 2011: Investment Funds Institute of Canada (IFIC)
IFIC submits comments in response to Notice 2011-34.
June 7, 2011: Investment Industry Association of Canada (IIAC)
IIAC submits comments in response to Notice 2011-34.
June 7, 2011: Investment Management Association (IMA)
IMA submits comments in response to Notice 2011-34.
June 7, 2011: The Japanese bankers Association (JBA)
JBA submits comments in response to Notice 2011-34.
June 7, 2011: Japan Securities Dealers Association (JSDA)
JSDA submits comments in response to Notice 2011-34.
June 7, 2011: Life Insurance Association of Japan (LIAJ)
LIAJ submits comments in response to Notice 2011-34.
June 7, 2011: Loan Syndications and Trading Association (LSTA)
The LSTA submits further comments after meeting with the Internal Revenue Service and echoes previously sent comment letters.
June 7, 2011: Managed Funds Association (MFA)
MFA provides further comments on Notice 2011-34.
June 7, 2011: The National Association of Pension Funds Limited (NAPF)
NAPF submits comments in response to Notice 2011-34.
June 7, 2011: Royal Bank of Canada and its subsidiaries (RBC)
RBC submits comments in response to Notice 2011-34.
June 7, 2011: Securities Industry and Financial Markets Association (SIFMA)
SIFMA submits comments in response to Notice 2011‐34.
June 7, 2011: Standard Life
Standard Life submits comments in response to Notice 2011-34.
June 7, 2011: Tax Executives Institute (TEI)
TEI submits comments in response to Notice 2011‐34.
June 6, 2011: Alternative Investment Management Association (AIMA)
AIMA provides further comments on the application of FATCA to funds and makes some submissions in respect of Notice 2011-34, which considers some priority concerns raised in previous comments.
June 6, 2011: Association of International Life Offices (AILO)
AILO submits comments in response to Notice 2011-34.
June 6, 2011: Banks "ABS", "ABM", "TBA", "BAP", "PERBANAS"
The banks, ABS, ABM, TBA, BAP, and PERBANAS submit jointly in response to Notice 2011-34.
June 6, 2011: Investment Company Institute (ICI)
ICI submits comments in response to Notice 2011-34.
June 6, 2011: Universities Superannuation Scheme Limited (USS)
USS submits comments in response to Notice 2011-34.
June 3, 2011: Bankers Association of the Republic of China (BAROC)
BAROC submits comments in response to Notice 2011-34.
June 3, 2011: Computershare Limited
Computershare Limited submits comments in response to Notice 2011-34.
June 2, 2011: Legal & General Group
Legal & General Group submits comments in response to Notice 2011-34.
June 1, 2011: American Council of Life Insurers (ACLI)
ACLI's request for inclusion of items for the Guidance Priority List for 2011-2012.
May 30, 2011: ALECTA (ALECTA)
ALECTA submits comments in response to Notice 2011-34.
May 24, 2011: America Chamber of Commerce in Peru (AmCham Peru)
AmCham Peru submits comments in response to Notice 2011-34.
May 20, 2011: Treasury Response to Senator Nelson
The Assistant Secretary (Tax Policy) of the United States Treasury responds to Senator Bill Nelson regarding proposed Treasury regulations.
May 16, 2011: Pershing LLC (Pershing)
Pershing submits comments in response to Notice 2011-34.
April 28, 2011: United States Treasury Responds to Senator Kay Bailey Hutchinson
On April 28th, the Assistant Secretary (Tax Policy) of the United States Treasury responded to Senator Kay Bailey Hutchinson.
April 12, 2011: Veritas Pension Insurance Company Ltd. ("Veritas")
Staffan Sevon and Nona Karppinen of Veritas Pension Insurance Co., commenting on guidance (Notice 2010-60) on the FATCA withholding and reporting provisions, has urged the IRS to consider defining the exemption from FATCA by methods other than a treaty-based method.
April 6, 2011: Hungarian Presidency and Commission (eu 2011.hu) Invite US to Dialogue on FATCA
In a letter sent to the US tax authorities, the Hungarian Presidency and the European Commission (eu 2011.hu) invited the US authorities to engage in a dialogue on how to best achieve the objectives of the US Foreign Account Tax compliance Act (FATCA).
April 4, 2011: TD Bank Group ("TD")
Peter van Dijk of TD Bank Financial Group (“TD), supplementing prior comments, has expressed concerns that preliminary guidance (Notice 2010-60) on the FATCA withholding and reporting provisions could lead to significant conflict-of-law issues and that FATCA's cost burdens are disproportionate to its expected benefits.
April 1, 2011: The Mexican Banking Association ("ABM") and the Mexican Securities Industry Association (AMIB)
The Mexican Banking Association (“ABM”) and the Mexican Securities Industry Association (“AMIB”), commenting on guidance (Notice 2010-60) on the Foreign Account Tax Compliance Act withholding and reporting provisions, have asked the IRS to consider issues the groups have identified, particularly regarding cases that present a conflict between FATCA and a foreign financial institution's domestic laws
March 31, 2011: United States Treasury Responds to Representative Posey
On March 31st, the Assistant Secretary (Tax Policy) of the United States Treasury responded to Representative Bill Posey.
March 28, 2011: American Institute of CPAs (AICPA)
The American Institute of Certified Public Accountants (AICPA) requests that guidance be issued on the numerous foreign trust issues arising from the application of the foreign account tax compliance act (FATCA) provisions included in the Hiring Incentives to Restore Employment (HIRE) Act of 2010, P.L. 111-147, enacted March 18, 2010.
March 10, 2011: British Bankers' Association (BBA)
BBA provides additional information requested by the United States Treasury Department and Internal Revenue Service.
March 5, 2011: New York State Bar Association
The New York State Bar Association Tax Section submits Report No. 1234, offering recommendations for future administrative guidance under Section 871(m) of the Internal Revenue Code of 1986, as amended.
February 14, 2011: American Bar Association Section of Taxation (ABA)
American Bar Association Section of Taxation’s (ABA) comments on the Foreign Account Tax Compliance Act (“FATCA”) Offset Provisions of the HIRE Act Relating to Beneficiaries of Trusts.
February 9, 2011: SPIROCO Consulting
SPIROCO Consulting's request for publication date of FATCA regulations.
February 1, 2011: Canadian Life and Health Insurance Association (the “CLHIA”)
In response to Notice 2010-60 request for comments, Canadian Life and Health Insurance Association (the “CLHIA”), submitted comments regarding the implementation of FATCA.
January 12, 2011: Universities Superannuation Scheme (USS)
In response to Notice 2010-60 request for comments, Universities Superannuation Scheme (USS), submitted comments regarding the implementation of FATCA.
January 10, 2011: American Bar Association Section of Taxation (ABA)
In response to Notice 2010-60 request for comments, American Bar Association Section of Taxation (ABA), submitted comments regarding the Grandfathering Rules in the HIRE Act and Notice 2010-60 .
January 7, 2011: American College of Trust and Estate Counsel ("ACTEC")
In response to Notice 2010-60 request for comments, American College of Trust and Estate Counsel ("ACTEC"), submitted comments regarding the implementation of FATCA.
December 30, 2010: Society of Trust and Estate Practitioners (STEP)
In response to Notice 2010-60 request for comments, Society of Trust and Estate Practitioners, submitted comments regarding the implementation of FATCA.
December 24, 2010: The Commonwealth Bank of Australia (the Bank)
In response to Notice 2010-60 request for comments, The Commonwealth Bank of Australia (the Bank), submitted comments regarding the implementation of FATCA.
December 23, 2010: The Association of Superannuation Funds of Australia (ASFA)
In response to Notice 2010-60 request for comments, The Association of Superannuation Funds of Australia (ASFA), submitted comments regarding the implementation of FATCA.
December 14, 2010: British Bankers' Association (BBA)
BBA’s follow-up on the meeting of November 23, 2010 with the United States Department of the Treasury and the Internal Revenue Service.
November 29, 2010: Association of Global Custodians (AGC)
AGC provides supplemental comments on selected issues regarding the FATCA provisions of the Hiring Incentives to Restore Employment Act (the “HIRE Act”), and the IRS Notice 2010-60.
November 26, 2010: Vienna Insurance Group (VIG)
In response to Notice 2010-60’s request for comments, Vienna Insurance Group (VIG) submitted comments regarding the implementation of FATCA.
November 16, 2010: New York State Bar Association Tax Section (NYSBA)
In response to Notice 2010-60’s request for comments, New York State Bar Association Tax Section (NYSBA) submitted comments regarding the implementation of FATCA.
November 12, 2010: American Bankers Association (ABA)
In response to Notice 2010-60’s request for comments, American Bankers Association (ABA) submitted comments regarding the implementation of FATCA.
November 12, 2010: Austrian Association of Investment Fund Management Companies (VOIG)
In response to Notice 2010-60’s request for comments, Austrian Association of Investment Fund Management Companies (VOIG) submitted comments regarding the implementation of FATCA.
November 12, 2010: BVI Bundesverband Investment und Asset Management (BVI)
In response to Notice 2010-60’s request for comments, BVI Bundesverband Investment und Asset Management (BVI) submitted comments regarding the implementation of FATCA.
November 12, 2010: European Banking Federation and Institute of International Bankers (EBF and IIB)
In response to Notice 2010-60’s request for comments, European Banking Federation and Institute of International Bankers (EBF and IIB) submitted comments regarding the implementation of FATCA.
November 12, 2010: European Fund Asset Management Association (EFAMA)
In response to Notice 2010-60’s request for comments, European Fund Asset Management Association (EFAMA) submitted comments regarding the implementation of FATCA.
November 12, 2010: Investment Management Association (IMA)
In response to Notice 2010-60’s request for comments, Investment Management Association (IMA) submitted comments regarding the implementation of FATCA.
November 11, 2010: American Chamber of Commerce in Luxembourg (ACCL)
In response to Notice 2010-60’s request for comments, American Chamber of Commerce in Luxembourg (ACCL) submitted comments regarding the implementation of FATCA.
November 10, 2010: Association of British Insurers
In response to Notice 2010-60’s request for comments, Association of British Insurers (ABI) submitted comments regarding the implementation of FATCA.
November 10, 2010: Australian Custodian Services Association (ACSA)
Australian Custodian Services Association (ACSA) submits comments in response to Notice 2010-60.
November 10, 2010: The States of Jersey
In response to Notice 2010-60’s request for comments, the States of Jersey, submitted comments regarding the implementation of FATCA.
November 5, 2010: Clearing House
In response to Notice 2010-60’s request for comments, Clearing House submitted comments regarding the implementation of FATCA.
November 3, 2010: Allianz SE
In response to Notice 2010-60’s request for comments, Allianz SE, submitted comments regarding the implementation of FATCA.
November 3, 2010: DST Systems and Boston Financial Data Services
In response to Notice 2010-60’s request for comments, DST Systems and Boston Financial Data Services, submitted comments regarding the implementation of FATCA.
November 2, 2010: Treasury Secretary Responds to FATCA Comment Letter
On November 2nd, Timothy Geithner, Secretary of the Treasury, responded to Congressman Wm. Lacy Clay’s September 13th letter requesting certain carveouts for FFIs to comply with FATCA.
November 1, 2010: Aviva Plc
In response to Notice 2010-60’s request for comments, Aviva plc submitted comments regarding the implementation of FATCA.
November 1, 2010: Alternative Investment Management Association (AIMA)
In response to Notice 2010-60’s request for comments by November 1, 2010, Alternative Investment Management Association (AIMA), submitted comments regarding the implementation of FATCA.
November 1, 2010: American Council of Life Insurers Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, American Council of Life Insurers (ACLI), submitted comments regarding the implementation of FATCA.
November 1, 2010: Australian Bankers’ Association Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Australian Bankers’ Association (ABA), submitted comments regarding the implementation of FATCA.
November 1, 2010: Canadian Bankers Association
In response to Notice 2010-60’s request for comments, Canadian Bankers Association (CBA), submitted comments regarding the implementation of FATCA.
November 1, 2010: Canadian Life and Health Insurance Association (CLHIA)
In response to Notice 2010-60’s request for comments, Canadian Life and Health Insurance Association (CLHIA) submitted comments regarding the implementation of FATCA.
November 1, 2010: Financial Services Council (FSC)
In response to Notice 2010-60’s request for comments, Financial Services Council (FSC) submitted comments regarding the implementation of FATCA.
November 1, 2010: Florida Bar Tax Section Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Florida Bar Tax Section (FBTS), submitted comments regarding the implementation of FATCA.
November 1, 2010: Government of the Cayman Islands Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Government of the Cayman Islands (GCI), submitted comments regarding the implementation of FATCA.
November 1, 2010: International Capital Market Association (ICMA)
In response to Notice 2010-60’s request for comments, International Capital Market Association (ICMA) submitted comments regarding the implementation of FATCA.
November 1, 2010: Investment & Life Assurance Group Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Investment & Life Assurance Group (ILAG), submitted comments regarding the implementation of FATCA.
November 1, 2010: Investment Trusts Association, Japan Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Investment Trusts Association, Japan (JITA), submitted comments regarding the implementation of FATCA.
November 1, 2010: Japanese Bankers Association Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Japanese Bankers Association (JBA), submitted comments regarding the implementation of FATCA.
November 1, 2010: Japan Securities Dealer Association Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Japan Securities Dealer Association (JSDA), submitted comments regarding the implementation of FATCA.
November 1, 2010: Konferenz der Geschäftsführer von Anlagestiftungen (KGAST)
In response to Notice 2010-60’s request for comments, Konferenz der Geschäftsführer von Anlagestiftungen (KGAST) submitted comments regarding the implementation of FATCA.
November 1, 2010: Managed Funds Association Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Managed Funds Association (MFA), submitted comments regarding the implementation of FATCA.
November 1, 2010: Scotiabank Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Scotiabank (Scotia), submitted comments regarding the implementation of FATCA.
November 1, 2010: Swiss Re
In response to Notice 2010-60’s request for comments, Swiss Re, submitted comments regarding the implementation of FATCA.
November 1, 2010: TD Bank Financial Group
In response to Notice 2010-60’s request for comments, TD Bank Financial Group, submitted comments regarding the implementation of FATCA.
November 1, 2010: The Investment Funds Institute of Canada Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, The Investment Funds Institute of Canada (IFIC), submitted comments regarding the implementation of FATCA.
October 29, 2010: Aegon N.V.
In response to Notice 2010-60’s request for comments, Aegon N.V. (AEGON), submitted comments regarding the implementation of FATCA.
October 29, 2010: Barclays Capital
In response to Notice 2010-60’s request for comments, Barclays Capital, submitted comments regarding the implementation of FATCA.
October 29, 2010: British Bankers’ Association Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, British Bankers’ Association (BBA), submitted comments regarding the implementation of FATCA.
October 29, 2010: European Federation for Retirement Provision
In response to Notice 2010-60’s request for comments, European Federation for Retirement Provision (EFRP), submitted comments regarding the implementation of FATCA.
October 29, 2010: European Private Equity and Venture Capital Association (EVCA)
The Public Affairs Executive (PAE) of the European Private Equity and Venture Capital Association’s (EVCA) Industry Response the Foreign Account Tax Compliance Act Provisions.
October 29, 2010: Florida International Bankers Association, Inc.
In response to Notice 2010-60’s request for comments, Florida International Bankers Association, Inc. (FIBA), submitted comments regarding the implementation of FATCA.
October 29, 2010: French Insurance Association
In response to Notice 2010-60’s request for comments, French Insurance Association (FFSA), submitted comments regarding the implementation of FATCA.
October 29, 2010: KPMG Vienna
In response to Notice 2010-60’s request for comments, KPMG Vienna submitted comments regarding the implementation of FATCA.
October 29, 2010: Spanish Association of Collective Investment Schemes and Pension Funds Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Spanish Association of Collective Investment Schemes and Pension Funds (INVERCO), submitted comments regarding the implementation of FATCA.
October 29, 2010: Standard Life
In response to Notice 2010-60’s request for comments, Standard Life, submitted comments regarding the implementation of FATCA.
October 29, 2010: The States of Guernsey
In response to Notice 2010-60’s request for comments, the States of Guernsey, submitted comments regarding the implementation of FATCA.
October 28, 2010: State Street Bank and Trust Company Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, State Street Bank and Trust Company (SSB), submitted comments regarding the implementation of FATCA.
October 28, 2010: Suva Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Suva (SUVA), submitted comments regarding the implementation of FATCA.
October 27, 2010: Building Societies Association Comment Letter
In response to Notice 2010-60’s request for comments by November 1, 2010, Building Societies Association (BSA), submitted comments regarding the implementation of FATCA.
October 27, 2010: Reinsurance Association of American Comment Letter
On October 27th, the Reinsurance Association of American (RAA) submitted comments to the Department of the Treasury and to the Internal Revenue Service (IRS) in response to Notice 2010-60.
October 12 and October 19, 2010: The World Tax Service and Tax Executives Institute Comment Letters
On October 19th and October 12th, Tax Executives Institute, Inc. (TEI) and World Tax Service (WTS), respectively, submitted comments to the Department of the Treasury and to the Internal Revenue Service (IRS) in response to Notice 2010-60.
September 13, 2010: Congressman Wm. Lacy Clay Comment Letter
On September 13th, Congressman Wm. Lacy Clay submitted comments to Timothy Geithner, Secretary of the U.S. Treasury, commenting on several specific provisions in the FATCA legislation.
September 8, 2010: Association of Global Custodians (AGC)
AGC provides comments on FATCA Provisions of the Hiring Incentives to Restore Employment (HIRE) Act and requests clarification of applicability of derivatives provisions to intermediaries.
September 3, 2010: RBC Financial Group
In response to Notice 2010-60’s request for comments, RBC Financial Group (RBC), submitted comments regarding the implementation of FATCA.
September 1 and September 8, 2010: The Association of Global Custodians and Center for Freedom and Prosperity Comment Letters
On September 8th and September 1st, the Association of Global Custodians (AGC) and Center for Freedom and Prosperity (CFP), respectively, submitted comments to the Department of the Treasury and to the Internal Revenue Service (IRS).
August 27, 2010: The Investment Trusts Association, Japan
In response to Notice 2010-60’s request for comments, The Investment Trusts Association, Japan (JITA), submitted comments regarding the implementation of FATCA.
August 18 and August 20, 2010: ABI and Allianz Comment Letters
On August 18th and 20th, the Association of British Insurers (ABI) and Allianz of America Corporation (Allianz), respectively, submitted in-depth comments to the Internal Revenue Service (IRS) asking for limitations to the current scope of Foreign Account Tax Compliance Act (FATCA).
August 13, 2010: The Clearing House Comment Letter
On August 13th, The Clearing House Association LLC, an association of the world’s largest commercial banks, submitted comments to the Internal Revenue Service (IRS) focusing on the FATCA rules applicable to U.S. Payors.
August 11 and August 16, 2010: ABA and SIFMA Comment Letters
On August 11th and 16th, the American Bar Association (ABA) Section of Taxation and the Securities Industry and Financial Markets Association (SIFMA), respectively, submitted in-depth comments to the Internal Revenue Service (IRS) asking for further clarification and guidance to the requirements under FATCA.
November 26, 2009: European Banking Federation (EBF) and the Institute of International Bankers (IIB)
The European Banking Federation (EBF) and the Institute of International Bankers (IIB) submit comments in response to Foreign Account Tax Compliance Act for 2009.
November 20, 2009: European Fund and Asset Management Association (EFAMA)
The European Fund and Asset Management Association (EFAMA) submits comments in response to Foreign Account Tax Compliance Act for 2009.
November 19, 2009: International Swaps and Derivatives Association, Inc. (ISDA)
The International Swaps and Derivatives Association, Inc. (ISDA) submits comments in response to Foreign Account Tax Compliance Act for 2009.
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