Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

FATCA is Chapter 4 of the Internal Revenue Code (IRC).   It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government.  To enforce its conscription, it contains a mechanism for financially penalizing FFIs that do not comply.

Developing regulatory and administrative guidance to implement FATCA took more than four years from the date of its



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