ARLINGTON, Va., Feb. 8, 2012 /PRNewswire-USNewswire/ --The U.S. Treasury has just released hundreds of pages detailing the new proposed regulations under the Foreign Account Tax Compliance Act ("FATCA"). The information reporting and withholding rules will have a pervasive impact on foreign financial institutions (FFIs) and on non-financial foreign entities (NFFEs). Navigating the New FATCA Proposed Regulations – What You Need to Know (February 15) will feature IRS and Treasury Department officials who participated in the drafting of the proposed regulations as well as knowledgeable private practitioners.
Registrants can expect a lively discussion and dissection of the proposed regulations and an update on related enforcement issues. There will be sufficient time for attendees to pose questions to the panelists.
Topics to be covered include:
How Will the Treasury Department Rationalize FATCA with Foreign Law Conflicts
The Scope of Withholdable Payments (including the inclusion of derivative payments) and Exceptions
Which Entities Are FFIs and NFFEs
The Information and Reporting Obligations of Becoming a Participating FFI or a Deemed Compliant FFI
Considerations to be taken into account in becoming Compliant or Non-Compliant with FATCA
How Will a U.S. Withholding Agent Know Whether to Withhold under Chapter 3 or Chapter 4
Special issues for banks, funds, insurance companies and trusts
Impact on U.S. multinationals
Treatment of Passthru Payments
The Compliance Aspects of FATCA
Understand the impact of FATCA on foreign financial institutions (FFIs), and what will be required for these institutions to prepare for FATCA's coming into effect.
Understand what the category of "nonfinancial foreign entity" (NFFE) will mean in practice.
Understand the scope of "withholdable payments," and how this characterization will affect transactions with FFIs and NFFEs.
Understand what payments may be covered by more than one withholding regime, and which regime to apply to payments with overlapping obligations.
Understand information and reporting obligations when paying an FFI, a "deemed-compliant FFI," or an FFE.
About the Speakers
Danielle Nishida joined the Internal Revenue Service as an attorney in the Office of Chief Counsel, International, in April 2009. She practices in income tax withholding and Subpart F, and is a principal draftsperson of the recent proposed regulations and other guidance under chapter 4 (FATCA). Prior to joining the Internal Revenue Service, she was an attorney with Burt, Staples, and Maner, LLP. Danielle is a graduate of Georgetown University (L.L.M, Taxation), Southwestern Law School (J.D.), and the University of California at Santa Barbara (B.A.).
Michael Plowgian is an Attorney-Advisor in the Office of the International Tax Counsel at the Department of the Treasury. Previously, he was an attorney in the tax group at King & Spalding LLP, where his practice focused on a wide range of domestic and international tax planning matters. Michael received his J.D. from Harvard Law School, a M.A.L.D. from the Fletcher School of Law and Diplomacy, and a B.A. from Denison University. Carol Tello is a partner in Sutherland Asbill & Brennan LLP's Washington office and a member of its Tax Practice Group where she focuses primarily on international tax matters. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters for both business entities and individuals. Much of her work has been for insurance companies in the cross-border context.
Her prior experience includes service in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). While at the IRS, she participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several Tax Court cases, and worked on various regulations and other guidance.
Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell's practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international insurance, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring.
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