The U.S. Treasury Department recently issued proposed regulations interpreting sections of the Internal Revenue Code (the Code) commonly referred to as the Foreign Account Tax Compliance Act (FATCA). The proposed regulations, which are lengthy and complex, raise reporting and withholding tax issues for trustees of non-U.S. trusts and, indirectly, U.S. citizen and resident beneficiaries of foreign trusts. These questions and answers address some of the most important of these issues.
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