International Tax

FATCA — Information Reporting and Withholding Under Chapter 4 (Portfolio 6565)

  • This Portfolio discusses the reporting and withholding requirements of chapter 4 (§1471–§1474) of the Internal Revenue Code.


These requirements generally require: (i) non-U.S. financial institutions to enter into agreements with the Internal Revenue Service under which they agree to identify and report U.S. account holders, and (ii) non-U.S. nonfinancial entities to disclose direct and indirect U.S. owners in certain circumstances, and which imposes a 30% withholding tax on certain payments to non-U.S. financial institutions and nonfinancial entities that do not comply with chapter 4’s requirements. This Bloomberg Tax Portfolio, FATCA — Information Reporting and Withholding Under Chapter 4 covers the chapter 4 withholding and reporting mechanism; the definitions and requirements chapter 4 places on both foreign financial institutions and nonfinancial entities (including rules under which entities with certain characteristics may qualify for exemption from some or all of chapter 4’s requirements); due diligence and reporting; refund procedures; the impact of intergovernmental exchange of information agreements; and specific issues affecting certain industries, such as asset management and insurance.

Table of Contents

I. Introduction and History
II. Rules Applicable to Withholding Agents
III. Rules Applicable to FFIs
IV. Special Considerations for Insurance Companies
V. Special Considerations for Asset Managers
VI. Rules Applicable to NFFEs
VII. Special Considerations for Other Industries and Entities
VIII. Payee Identification Procedures
IX. Intergovernmental Agreements
X. Liability for Withheld Tax and Refund Procedures
XI. Other FATCA Provisions

Stephen Nauheim
Managing Director
PricewaterhouseCoopers LLP
Nils Cousin
Manager Of International Tax
PricewaterhouseCoopers LLP
Candace Ewell
PricewaterhouseCoopers LLP
Robert Limerick
Managing Director, Global Information Reporting
PricewaterhouseCoopers LLP
Jon Lakritz
Managing Director
Rebecca Lee
PricewaterhouseCoopers LLP
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