Wednesday, December 14, 2011

Professor Dick Harvey, Jr., gives us a wonderful article on issues of FATCA

Professor Dick Harvey, Jr. has given us a wonderful article on the withholding issues of FATCA. We learn the enforcement buzz word/issue of the new century:   will  compliance-challenged  (Dick calls them “tax cheats”) US taxpayers continue to beat the system by moving their foreign accounts to foreign banks which don’t care if they can’t sell US securities. They may decide to not cough up the names and SSN’s of their “U.S. persons.” Those foreign banks who say “hell no!” will be known as NP-FFI’s: non-participating foreign financial institutions and the issue Professor Harvey points out, is whether the withholding objective of FATCA is evaded through certain pass through payments to NP-FFI’s investing exclusively in non-US assets?


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