What are some of the provisions of the Hire Act of 2010 with respect to Foreign Account Act Compliance Act (FATCA)?
The Hiring Incentives to Restore Employment (HIRE) Act of 2010 "contained a revenue offset provision referred to as the Foreign Account Tax Compliance Act (FATCA)."
FATCA legislation "creates a host of new anti-abuse measures designed to deter U.S. individuals from attempting to hide assets overseas and further delays the effective date of the worldwide allocation of interest provision."
FATCA contains provisions dealing with the following items;
a) Expanded withholding rules and additional reporting requirements for foreign financial institutions and non-financial foreign entities,
b) Disclosure of information with respect to foreign financial assets,
c) Penalty for underpayments attributable to undisclosed foreign financial assets,
d) Statute of limitations for omission of income in connection with foreign assets,
e) Information reporting for passive foreign investment companies,
f) E-filing of certain returns related to withholding on foreign transfers,
g) Foreign trusts treated as having U.S. beneficiary,
h) Uncompensated use of trust property,
i) Reporting requirement for U.S. persons treated as owners of foreign trusts,
j) Penalty for failure to report information or file return concerning certain foreign trusts,
k) Substitute dividends and dividend equivalent payments received by foreign persons,
l) Repeal of certain foreign exceptions to registered bond requirements, and
m) Interest expense sourcing for worldwide affiliated groups.