The time for mobilisation is now

On March 18, 2010, the Foreign Account Tax Compliance Act of 2009 ("FATCA") became law as part of the Hiring Incentives to Restore Employment ("HIRE") Act in the U.S.

The proposal will enhance the proper collection of US tax imposed on the income of U.S. persons, where that income is generated in the U.S. Further, it will ensure that all financial institutions, wherever based, operate a system that produces information to enable the U.S. to impose its tax laws on U.S. persons.

The magnitude of the effort required has been acknowledged by regulators and as such, the lead time to commencement is from now until 1 January 2013, with agreements needing to be entered with the IRS by 30 June 2013.

To gain an understanding of what FATCA means for you we have prepared a Briefing Note and Frequently Asked Questions.