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IRS Publishes Final, Temporary FATCA Coordination Regs

JAN. 6, 2017

T.D. 9808; 2017-5 IRB 580; 82 F.R 2046-2122

DATED JAN. 6, 2017
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Citations: T.D. 9808; 2017-5 IRB 580; 82 F.R 2046-2122
The IRS has published final and temporary regulations (T.D. 9808) regarding withholding of tax on some U.S.-source income paid to foreign persons, information reporting and backup withholding regarding payments made to U.S. persons, and portfolio interest paid to nonresident alien individuals and foreign corporations.

Effective January 6, the final regs adopt proposed regs (REG-134361-12) under chapters 3 and 61 and sections 871, 3406, and 6402 issued in March 2014. The corresponding temporary regs (T.D. 9658) are removed. In some cases, the changes to the 2014 temporary regs made by the final and temporary regs are coordinated with concurrently issued final and temporary regulations (T.D. 9809, REG-103477-14) under chapter 4.

The new temporary regs provide additional rules under chapter 3 and also serve as the text of concurrently issued proposed regulations (REG-134247-16). The temporary regs include rules on claims for a reduced rate of withholding under an income tax treaty. The temporary regs affect persons making payments of U.S.-source income to foreign persons.

Full Text Citations: T.D. 9808; 2017-5 IRB 580; 82 F.R 2046-2122; Doc 2016-25196 ; 2017 TNT 1-12 2017 TNT 1-12: IRS Final Regulations

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