Despite several delays, it seems almost certain that the “Foreign Account Tax Compliance Act”¹ (FATCA) will finally go into effect on July 1, 2014. FATCA is a withholding tax regime designed to prevent U.S. taxpayers from hiding income offshore and avoiding U.S. taxes. FATCA’s impact will need to be considered in most cross-border transportation finance transactions. While the FATCA rules are complex and a thorough treatment of them is beyond the scope of this article, below are some key issues relating to the impending effectiveness of FATCA that are important to keep in mind.

When Do the FATCA Rules Go Into Effect?

After several delays and extensions, the FATCA rules are currently scheduled to become effective with respect to payments of interest, dividends and rentals and other similar payments made on or after July 1, 2014. While this deadline has been extended several times, the Internal Revenue Service (IRS) has repeatedly stated that no further delays are anticipated.² Obligations outstanding on July 1, 2014 will be “grandfathered,” and the FATCA rules will not apply to payments made under these pre-existing obligations,³ unless such obligations are substantially modified after that date.4 Withholding on payments of “gross proceeds” is not set to begin until after December 31, 2016. Although FATCA withholding will not apply until July 1, 2014, parties who are currently negotiating transportation finance transactions are typically taking into account the possible application of FATCA withholding in the future and are documenting such transactions accordingly.

Overview of the Rules

In general, FATCA imposes a 30% withholding tax on “withholdable payments” to certain non-U.S. persons (foreigners). Withholdable payments broadly include any payment of: (a) U.S. source interest (including OID), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments and other fixed and determinable annual or periodical gains, profits or income, or (b) U.S. source gross proceeds from the sale or other disposition of any property of a type that can produce U.S. source interest or dividends.⁵

Since it is the payor that is obligated to withhold from payments if withholding is required under FATCA, any payor making a payment to a foreigner should confirm that such payment is either (a) related to an obligation to which FATCA does not apply (such as a grandfathered obligation or a non-U.S. source obligation), or (b) made to a foreigner who can provide proof of exemption from FATCA withholding.

Determining U.S. Source

Determining the source of interest payments is usually straight forward, as the jurisdiction of the borrower generally determines the source.⁶ However, in the complex financing structures often utilized for transportation finance transactions, a deeper analysis may be required. For instance, in certain cross-border structured finance transactions a nominal U.S. borrower is used to “own” and “lease” the aircraft to a foreign airline lessee. However, for U.S. tax purposes this borrower is merely an agent, or conduit, for the lessee and the lessee would be treated as the owner of the aircraft. In these circumstances, notwithstanding the nominal U.S. borrower, the parties take the position that, since the true borrower is the foreign airline, the interest is not U.S. source and thus not subject to the FATCA rules.

While sourcing rental payments may seem straightforward at first glance, as you generally look to the jurisdiction where the asset is used, the analysis become trickier for transportation equipment like aircraft.⁷ As aircraft may be used in many jurisdictions, the Internal Revenue Code provides special rules treating as U.S. source: (a) 100% of the income attributable to flights that begin AND end in the U.S., and (b) 50% of the income attributable to flights not described in (a) which begin OR end in the U.S.⁸ Thus, even aircraft leased to a foreign carrier could generate U.S. source rental income if, for example such foreign carrier operates flights to the U.S. or has the ability to sublease the aircraft to a U.S. carrier. For these reasons, it is prudent to include FATCA provisions in aircraft leases with foreign carriers, even where such leases do not initially seem as though they will generate U.S. source income.⁹

Avoiding Withholding Under FATCA

A payor of U.S. source income will need to ensure that its payee is exempt from FATCA withholding. Payments to U.S. entities are generally exempt from FATCA withholding and a payor should collect a Form W-9 or other appropriate evidence of U.S. status when making a payment of U.S. source income to a U.S. entity in order to confirm FATCA withholding is not required.

FATCA is directed primarily at “foreign financial institutions” (FFIs), but also covers “non-financial foreign entities” (NFFEs). While there are various methods for FFIs and NFFEs to be exempt, several of the most common ones are discussed below.

An FFI may be exempt either by reason of the government of its home jurisdictions having entered into an intergovernmental agreement (IGA) with the U.S. or by entering into an agreement with the IRS to report U.S. account holders. There are two types of IGAs: (a) Model 1 IGAs, whereby the FFIs report to their local government, which shares the relevant information with the IRS, and (b) Model 2 IGAs, whereby the FFIs report directly to the IRS. The U.S. and numerous foreign jurisdictions have concluded IGAs¹⁰ and FFIs in a country with an IGA can obtain a “global intermediary identification number” (GIIN), which can be supplied to payees to evidence exemption.

NFFEs can obtain exemption from FATCA by confirming they are the beneficial owner of the payment and reporting their substantial (10% or more) U.S. owners, if any. Reporting information includes name, address and U.S. taxpayer identification number (TIN) of U.S. owners. Under certain circumstances the NFFE can report its ownership information to the IRS rather than the payee. In addition, certain classes of NFFEs are exempt, such as publicly traded companies or companies predominantly engaged in an active business. It remains to be seen whether a leasing company will be considered to be engaged in an active trade or business (and what tests will be applicable to qualify for this status).

When making a payment of U.S. source income to a foreigner, a payor should collect a Form W-8BEN-E to confirm the payee’s FATCA exemption status.¹¹

Negotiating and Documenting FATCA Provisions

Bad news – you will probably need to get tax lawyers involved. Many, if not most, parties seem to be taking a cautious approach and are inserting FATCA provisions where there is any possibility that the payments could be U.S. source currently or in the future. The Loan Market Association has drafted a variety of “standard” provisions but cautions that there are no simple drafting solutions.

Approaches to the allocation of risk vary from a shared approach to an allocation of all of the risk to either the borrower or the lender, in the case of a secured financing, or the lessee or the lessor, in the case of a lease. Borrowers and lessees often make the argument their lender or lessor, as the case may be, should “come to the table” as FATCA compliant and be able to demonstrate such compliance or suffer withholding if they cannot. Lessors and lenders, on the other hand, often make the argument that they should not be at risk for changes in U.S. law. However, these perspectives should not be over emphasized as each transaction needs to be examined in the light of the particular parties and circumstances. In the short run, the negotiation and documentation of these provisions will continue to require time and effort. In the long run, the terms and allocations of risk will likely standardize in a manner similar to how U.S. withholding tax provisions have standardized over the years.

¹ I.R.C. §§ 1471-1474.

² “Final” FATCA regulations were published in the Federal Register on March 6, 2014 (Fed Reg Vol 79 No 44 p. 12812).

³ Technically the obligation needs to be issued before July 1, 2014 and outstanding on July 1, 2014 in order to be grandfathered, and an obligation issued on July 1, 2014 does not qualify for the exception.

⁴ A substantial modification may be triggered by, among other things, a change in interest rate, maturity or obligor.

⁵ Unlike traditional withholding rules, the FATCA regime will eventually apply to proceeds from the sale or other disposition of instruments producing U.S. source interest or dividends. The rules are broad enough to include principal payments on debt instruments.

⁶ I.R.C. § 861(a)(1).

⁷ I.R.C. § 861(a)(4) covering rentals generally.

⁸ I.R.C. § 863(c) covering transportation income which includes aircraft rentals (I.R.C. § 863(c)(3)(A)).

⁹ Where there is a foreign lessee with no other U.S. payor connection, it remains to be seen how the IRS will enforce the FATCA withholding obligation against the foreign lessee with minimal U.S. contacts (e.g., such as merely flying back and forth to and from the U.S.).

¹⁰ The U.S. has concluded Model 1 IGAs with: Canada (2-5-2014), Cayman Islands (11-29-2013), Costa Rica (11-26-2013), Denmark (11-19-2012), Finland (3-5-2014), France (11-14-2013), Germany (5-31-2013), Guernsey (12-13-2013), Hungary (2-4-2014), Ireland (1-23-2013), Isle of Man (12-13-2013), Italy (1-10-2014), Jersey (12-13-2013), Malta (12-16-2013), Mauritius (12-27-2013), Mexico (11-19-2012), Netherlands (12-18-2013), Norway (4-15-2013), Spain (5-14-2013) and the United Kingdom (9-12-2012); and Model 2 IGAs with: Bermuda (12-19-2013), Chile (3-5-2014), Japan (6-11-2013) and Switzerland (2-14-2013).

¹¹ A new W-8BEN-E form will be used for foreign entities and will include the appropriate information to demonstrate FATCA compliance or an exemption from FATCA withholding. Note that a proper exemption from “regular” U.S. withholding will also need to be documented. It is possible that a payee may be exempt from FATCA withholding but not regular withholding.

The post Get the FATCA Outta Here? Not Likely. – Foreign Account Tax Compliance Act appeared first on The National Law Forum.

When:

June 17 – 18, 2013

Where:

The Princeton Club
15 West 43rd Street
New York, NY 10036
212-596-1200

The post FATCA Implementation Summit – June 17, 2013 appeared first on The National Law Forum.

On January 17, 2013, the Internal Revenue Service (IRS) published final regulations under the Foreign Account Tax Compliance Act (FATCA), which are effective immediately.  Congress enacted FATCA in 2010 to make it more difficult for U.S. taxpayers to conceal assets held in offshore accounts.  In order to discover information about offshore accounts, FATCA imposes significant reporting obligations on both non-U.S. foreign financial institutions (FFIs) and U.S. taxpayers holding foreign financial accounts.  A non-U.S. retirement plan may be subject to FATCA reporting responsibilities as an FFI unless there is an available exemption.  Failure to comply with applicable reporting requirements may trigger substantial withholding taxes and penalties.  This On The Subject summarizes what employers need to know about FATCA for both plans and participants.

Plan-Level Requirements

Foreign Financial Institutions

An FFI must register with the IRS by October 25, 2013, and formally agree to implement procedures for identifying and disclosing information about financial accounts held by its U.S. customers.  Unfortunately, a non-U.S. retirement plan is generally included in the broad definition of an FFI, which means it will be required to register and disclose information about its U.S. taxpayer participants if it is not exempt from FATCA.  Complying with FFI reporting rules requires significant due diligence to identify account holders who are U.S. taxpayers.  Failure by a non-exempt FFI to comply will subject it to a 30 percent withholding tax on certain U.S. source income and on the gross proceeds from the sale of certain assets that generate U.S. source income (such as debt and equity instruments).

Exemptions for Retirement Plans

The final regulations provide important exemptions from FATCA’s reporting and withholding requirements for some, but not all, non-U.S. retirement plans.  In response to public comments, the final regulations revised certain exemption requirements under the proposed regulations to broaden the types of retirement plans that will be exempt from FATCA.  Important exemptions include the following categories.

Broad Participation Retirement Plans.  A non-U.S. retirement plan established to provide retirement, disability and/or death benefits for current or former employees and designated beneficiaries will be exempt from FATCA if these qualifications are met:

• No single beneficiary has a right to more than 5 percent of the plan’s assets.
• It is subject to government regulation and provides annual information reporting about its beneficiaries to the tax authorities in the country in which it is established or operates (its home country).
• It satisfies at least one of the following requirements:
  • It is exempt from tax on investment income in its home country because of its status as a retirement or pension plan.
  • It receives at least 50 percent of its contributions (other than certain transfers) from sponsoring employers.
  • Distributions or withdrawals (other than certain transfers or rollovers) are only allowed upon the occurrence of specified events related to retirement, disability or death, or penalties apply to distributions made prior to such specified events.
  • Employee contributions (other than certain make-up contributions) are limited by reference to earned income or may not exceed $50,000 annually

Narrow Participation Retirement Plans.  A non-U.S. retirement plan established to provide retirement, disability and/or death benefits for its current or former employees and designated beneficiaries will be exempt from FATCA if these qualifications are met:

• The plan has fewer than 50 participants.
• The plan is sponsored by one or more employers that are not investment entities or passive non-financial foreign entities.
• The plan is subject to government regulation and provides annual information reporting about its beneficiaries to the relevant tax authorities in its home country.
• Participants not resident in the plan’s home country are not entitled to more than 20 percent of the plan’s assets.
• Employee and employer contributions to the plan (other than transfers from certain retirement savings accounts or other exempt retirement plans) are limited by reference to earned income and compensation, respectively.

Treaty-Qualified Retirement Plans.  A non-U.S. retirement plan established in a country with which the United States has an income tax treaty in force will be exempt from FATCA reporting and withholding if it is entitled to benefits under such treaty on income derived from U.S. sources as a resident of that country that satisfies applicable benefit limitation requirements and is operated principally to administer or provide pension or retirement benefits.  Tax treaties typically include specific definitions regarding when a person is treated as a resident of a country.  Note that this exemption does not require a non-U.S. retirement plan to qualify for favored tax treatment either in the United States or in the country subject to the tax treaty with the United States.

401(a)-Type Plans.  A pension plan that would meet the requirements of Section 401(a) of the Code if it were funded by a trust created or organized in the United States is exempt from FATCA reporting and withholding.

Investment Vehicles Designed Exclusively for Retirement Plans.  Investment vehicles that exclusively invest funds of one or more types of retirement plans described above or of certain types of retirement savings accounts are exempt from FATCA reporting and withholding.

Even if exempt from FATCA reporting, a non-U.S. retirement plan is required to certify its status on an IRS Form W-8BEN (or suitable substitute) in order to avoid withholding and, in some cases, must also provide documentary evidence supporting the exemption.  The IRS has not yet published revisions to W-8BEN that reflect the final regulations, so it remains to be seen what type of general documentary evidence will be required.

Intergovernmental Agreements

FATCA raises many compliance issues for a non-exempt FFI and can pose a catch-22 for an FFI, requiring it to either violate local law restrictions relating to the disclosure of account information or bear the risk of FATCA liability exposure.  An intergovernmental approach to FATCA solves these compliance issues, significantly reduces FFI costs and simplifies tax administration.  In order to implement FATCA’s information reporting requirements, the U.S. Treasury Department (Treasury) worked with several countries to develop model intergovernmental agreements (IGAs).  Under one such model, an FFI reports information about financial accounts held by U.S. taxpayers directly to its government, and the foreign government then provides such information to the United States (a Model 1 IGA).  In order to comply with any laws impeding a foreign government’s ability to report information directly to the United States, another model allows the signing country’s FFIs to report directly to the Treasury (a Model 2 IGA).

Each of the model IGAs includes an annex in which the signing countries may list categories of entities that will be exempt from FATCA reporting requirements.  Annex II typically lists the retirement plans that will be exempt from FATCA’s withholding and reporting requirements irrespective of whether any of the other exemptions described above are available.  For example, it was unclear under the FATCA proposed regulations whether certain pension plans established under UK law would have been exempt from FATCA; however, the IGA signed by the United Kingdom and the United States in September 2012 clarifies that most UK pension plans will be exempt from FATCA reporting requirements.

As of March 15, 2013, Denmark, Germany, Ireland, Italy, Mexico, Norway, Spain, Switzerland and the United Kingdom have initialed or signed IGAs with the United States.  It is likely that other countries will adopt IGAs, as the Treasury is engaged with more than 50 countries and jurisdictions to implement the reporting and withholding provisions of FATCA.  It is anticipated that IGAs will be entered into with the following countries in the coming months: Canada, Finland, France, Guernsey, Isle of Man, Japan, Jersey and the Netherlands.

Impact of Intergovernmental Agreements on U.S. Retirement Plans

The model IGAs are generally structured to be “reciprocal” in nature, meaning that the United States would agree to provide the same type of information about financial accounts held in the United States by the signing country’s taxpayers to the signing country.  For example, the IGA with the United Kingdom requires the United States to report information about certain depository accounts and certain narrowly defined financial accounts held in the United States by residents of the United Kingdom.  In addition, it commits the United States to adopt regulations to ultimately achieve an equivalent level of information being provided by the United States and the United Kingdom.  Thus, under such reciprocal IGAs, it is not unlikely that a U.S. retirement plan eventually will be required to disclose information about non-U.S. taxpayer participants if the plan is not otherwise exempt from FATCA reporting.  It remains to be seen what new reporting requirements may be imposed upon U.S. retirement plans.

Next Steps

Employers should evaluate whether their non-U.S. retirement plans qualify for a FATCA exemption under the final regulations.  With respect to any non-exempt plans, employers should contact plan trustees regarding steps being taken to address potential FATCA coverage and monitor developments that may affect reporting obligations, including whether the home country appears likely to sign an IGA with the United States.

Individual-Level Requirements

In addition to the plan-level reporting for certain non-U.S. retirement plans, U.S. taxpayers participating in a non-U.S. retirement plan often have reporting obligations to the IRS under FATCA.  In general, Section 6038D of the Internal Revenue Code requires U.S. citizens, resident aliens and certain nonresident aliens with U.S. source income to report beneficial ownership of “foreign financial assets” with an aggregate value of more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year (although higher thresholds apply to U.S. taxpayers who file joint tax returns or reside abroad).  “Foreign financial assets” have been interpreted to include interests under a foreign pension or deferred compensation plan, and may also include foreign equity awards.  Covered individuals are required to report these interests on IRS Form 8938 (as an attachment to the annual income tax return).  Section 6038D reporting currently is effective and was required beginning in the 2012 tax filing season (i.e., by April 17, 2012, unless an extension was granted).  Click here for a helpful set of Q&As published by the IRS addressing basic questions under IRS Form 8938.  The FATCA final regulations do not change any reporting obligations that apply to individuals.

There is no exemption for a covered individual with an interest in a non-U.S. retirement plan from filing Form 8938 merely because the plan that is a foreign financial interest itself falls into one of the FATCA exemptions described above.  In addition, the obligation of a covered individual to report under Form 8938 is separate from and in addition to reporting under the Report of Foreign Bank and Financial Accounts (FBAR).  A U.S. individual may have FBAR filing obligations merely by having signature authority over foreign financial accounts with an aggregate value above $10,000.  In contrast, Section 6038D and Form 8938 focus on equitable ownership of interests in certain foreign assets with different reporting thresholds depending upon the individual’s filing and residency status.

Covered individuals who fail to meet the Form 8938 reporting requirements are potentially subject to steep penalties.  Section 6038D provides for to up to $50,000 in penalties.  In addition, a 40 percent understatement penalty applies to any tax attributable to the non-disclosed assets.  While there is currently no IRS correction program for failure to file a Form 8938 for 2012, covered individuals who have failed to meet such reporting requirements with respect to an interest in a plan that is a foreign financial asset may wish to consider amending their prior tax returns.

Next Steps

Employers should consider providing assistance to their employees who may be subject to Section 6038D reporting obligations.  Assistance involves identifying foreign plans that may be subject to this reporting requirement and providing information on what values may be reported on Form 8938.  Although it is the individual’s responsibility to meet any reporting requirements under FATCA, there are also related corporate governance risks for the multinational employer if executive and other employees are not properly reporting U.S. taxes on plan interests outside the United States.  In this regard, it is important to keep in mind that the IRS has identified foreign funded retirement plans as a potential area of tax avoidance and is working on guidance with respect to the taxation of these plans.

Compliance with FATCA obligations is an important part of providing employee benefits outside of the United States for a multinational employer.  Failure to take these obligations into account as part of compliance and risk management activities can result in adverse exposure to the company and its executive, particularly if there is a related significant underpayment of U.S. income tax.

© 2013 McDermott Will & Emery

The post What You Need to Know About Foreign Account Tax Compliance Act’s (FATCA) Impact on Non-U.S. Retirement Plans appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.

Implementing FATCA compliance standards will come with challenges for financial institutions across the globe. It is imperative that organizations and individuals, who oversee FATCA compliance regulations adequately prepare, understand and comply with the standards of the new regulations. The marcus evans FATCA Compliance Conference, December 4-5, 2012 in New York, NY will focus on the main concerns and issues with the upcoming compliance expectations under FATCA and analyze the existing requirements and how financial organizations can adequately comply.

Join industry leading experts, including key speakers:

• Kathleen G. Dugan, Senior Vice President, Corporate and Institutional Services at Northern Trust
• Jason Vasquez, Senior VP, BSA/AML Officer at Provident Bank
• Kevin V. Sullivan, Head, North American Tax Operations Vice President at BNP Paribas Corporate & Investment Banking
• Bill Holmes, Director, International Data Management at US Internal Revenue Services
• Michael N. Obolensky, Senior Regulatory Counsel at Lloyds Bank

Attending this premiere marcus evans conference will enable you to:

• Discuss the fundamental challenges with FATCA compliance as it relates to clarification of terms and definitions
• Review the advantages of leveraging current Anti-Money Laundering (AML) programs in order to implement FATCA compliance
• Discuss FATCA’s impact on insurance companies application and implementation process
• Evaluate the growing concern of violating privacy rules as it relates to disclosure of client information

Attendees will benefit from a dynamic peer-to-peer presentation format consisting of workshops, interactive panel discussions and case studies. Each network and interactive session will be followed by 10-15 minutes of Q&A affording all in attendance an opportunity to get the answers to questions affecting their business. Moreover, 4+ hours of networking opportunities will supply attendees with benchmarking and best practices.

For more information, please contact Michele Westergaard at 312-540-3000 ext. 6625 or Michelew@marcusevansch.com.

For a full list speakers and topics, visit http://www.marcusevans-conferences-Northamerican.com/FATCA_NLRB

The post FATCA Compliance Conference – December 4-5, 2012 appeared first on The National Law Forum.