"The Impact of the US Foreign Account Tax Compliance Act (FATCA) on Pension Plans and Incentive Programs"
Date of Live Session: Tuesday, May. 15, 2012
Replay: Available anytime until June 15, 2012
Live Session Time:
11:00 AM Eastern Daylight Savings Time (Toronto, Canada)
4:00 PM UK Time
5:00 PM Central European Time
The IPEBLA Teleconference Committee has assembled an expert panel of speakers who will address the topic, “The Impact of the US Foreign Account Tax Compliance Act (FATCA) on Pension Plans and Incentive Programs".
This Teleconference will be conducted in English.
Rosalind Connor, Taylor Wessing LLP, UK
James Klein, Pillsbury Winthrop Shaw Pittman LLP, United States
Brian Buggy, Matheson Ormsby Prentice, Ireland
As part of the efforts of the US to find all US taxpayers with assets outside the US, The Foreign Account Tax Compliance Act (FATCA) was passed in 2010. This broad and complex piece of legislation applies very high taxes on US source investment income held by “Foreign Financial Institutions” (FFI) unless they disclose US taxpayers holding assets through the FFI. FATCA added a number of complex sections to the US Internal Revenue Code, and in February the IRS proposed extensive regulations (almost 400 pages) interpreting the Act.
While the thrust of FATCA is on FFIs, there has also been great concern on the part of pension funds and employers sponsoring funded incentive programs, including equity-based incentives. While the proposed regulations did a great deal to relieve issues around nonUS pension plans, there are still serious concerns for some pension plans and incentive programs. In addition, the new FATCA enforcement provisions applicable to individuals, are being implemented by the IRS through a recently issued a new form (without ending the use of other forms) for individuals to report their nonUS assets.
The speakers will cover issues such as:
- Basic structure and objectives of FATCA
- Application to nonUS pension plans
- Comment letters on the application of FATCA to pension plans
- The proposed regulations on FATCA and pension plans
- Application of FATCA to equity compensation and other incentive programs
- Interplay of other US requirements, including the Report on Foreign Bank and Financial Accounts (FBAR)
- Application of new US tax filings for individuals and longstanding tax issues for individuals participating in nonUS pension plans and incentive programs
- Interplay of FATCA and the US income tax treaty network.
Length of teleconference:
The panel discussion will run for approximately 70 minutes, followed by a 20-minute question and answer session.
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