IRS Issues Final Regulations to the Foreign Account Tax Compliance Act
By ANDREW M. SHORT & MELVIN M. PERALTA
This alert provides recent updates on the development of the Foreign Account Tax Compliance Act ("FATCA"), including the release of the much anticipated final regulations to FATCA. The final regulations modify and supplement proposed regulations released by the IRS and Treasury in early 2012. The final regulations represent the latest milestone in the evolution of FATCA. Nonetheless, some issues remain unresolved, including the publication of guidance regarding "foreign passthru payments." This alert also discusses the interaction of the final regulations with intergovernmental agreements entered into between the United States and various foreign governments.