Transcription of FATCA Final Regulations: Definitions List
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FATCA Final Regulations: Definitions List
FATCA Final regulations : Definitions ListBy Craig CohenChapter 4 of the Internal Revenue Code and the Treasury regulations thereunder commonly known as the Foreign Account Tax Compliance Act, or FATCA consists of a complex web of withholding and reporting mechanics. These rules and regulations are expressed in a language of defined terms unique to FATCA , populated largely with internal cross-references and nearly incomprehensible to even the most experienced tax practitioner. As such, this concise list of the most commonly used defined terms under the Final FATCA Treasury regulations is in tended to act as a stand-alone reference for understand ing and applying the key terms and concepts under FATCA . Of course, these materials are not intended to be a substitute for a careful reading of the relevant Treasury regulations , and for this reason each entry includes a citation. Defined terms used elsewhere in this Definitions list are highlighted in content of this article was originally published in Tax Notes International, Volume 70, Number 8, May 20, Final regulations : Definitions Final Regulation: Definitions ListCraig Cohen is senior counsel with Allen & Overy in New YorkAccount holder: section (a)(3)(i): the person listed or identified as the holder of a financial account with the FFI that maintains the financial account, regardless of whether such person is a flow-through entit
www.allenovery.com 1 FATCA Final Regulations: Definitions List By Craig Cohen Chapter 4 of the Internal Revenue Code and the Treasury regulations thereunder — commonly known as the Foreign
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