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The Journal of Structured Finance

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FATCA’s Impact on Structured Products

Denise Hintzke and Christopher S. Brown
The Journal of Structured Finance Summer 2011, 17 (2) 17-22; DOI: https://doi.org/10.3905/jsf.2011.17.2.017
Denise Hintzke
is the foreign account tax compliance global and U.S. tax leader at Deloitte Tax LLP in New York, NY.
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  • For correspondence: dhintzke@deloitte.com
Christopher S. Brown
is a senior tax manager in the Financial Services Tax Group of Deloitte Tax LLP in New York, NY.
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  • For correspondence: chrisbrown@deloitte.com
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Abstract

On March, 18, 2010, President Obama signed the Hiring Incentives to Restore Employment Act (HIRE Act) into law. While the main focus of the law is to provide incentives for hiring and retaining unemployed workers, it also contains provisions to address offshore tax evasion. These provisions, commonly referred to as the Foreign Account Tax Compliance Act (FATCA), add an entirely new and significant U.S. withholding and information reporting tax regime to the Internal Revenue Code. FATCA was enacted to ensure there is no gap in the ability of the U.S. government to determine the ownership of U.S. assets in foreign accounts and to prevent offshore tax abuses by U.S. persons—in particular to prevent a U.S. person from escaping U.S. tax liability by owning U.S. assets through foreign accounts. During the last decade, U.S. persons, including financial institutions, corporations, and individuals, have invested trillions of dollars into global loan syndications and participations, as well as multi-party repos and swap or derivative products. Now banks and other financial sponsors will have to determine how FATCA and the preexisting U.S. tax information reporting and withholding rules interact and are applied to cross-border structured financial products. This article explores the impact of FATCA on cross-border loan participations, syndications or multi-party repo transactions, and on notional principal contracts or derivatives.

TOPICS: Legal/regulatory/public policy, legal and regulatory issues for structured finance

  • Copyright © 2011 Deloitte Development LLC. All rights reserved.
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The Journal of Structured Finance: 17 (2)
The Journal of Structured Finance
Vol. 17, Issue 2
Summer 2011
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FATCA’s Impact on Structured Products
Denise Hintzke, Christopher S. Brown
The Journal of Structured Finance Jul 2011, 17 (2) 17-22; DOI: 10.3905/jsf.2011.17.2.017

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FATCA’s Impact on Structured Products
Denise Hintzke, Christopher S. Brown
The Journal of Structured Finance Jul 2011, 17 (2) 17-22; DOI: 10.3905/jsf.2011.17.2.017
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  • Article
    • Abstract
    • BACKGROUND
    • U.S. WITHHOLDING AND REPORTING OF LOAN PARTICIPATIONS OR SYNDICATED LOANS/REPOS OUTSTANDING ON OR BEFORE MARCH 18, 2012
    • FATCA WITHHOLDING AND REPORTING OF LOAN PARTICIPATIONS OR SYNDICATED LOANS/REPOS ISSUED AFTER MARCH 18, 2012
    • DERIVATIVES OR SWAPS
    • ENDNOTES
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