HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

REG–130967–13, page 884. Sections 1471 through 1474 of the Internal Revenue Code, commonly known as FATCA, generally require a U.S. withholding agent to withhold tax on certain payments to a foreign financial institution (FFI) that has not agreed to provide the IRS with certain information regarding its United States accounts. Under FATCA, a U.S. withholding agent must also withhold tax on certain payments to a nonfinancial foreign entity (NFFE) that has not provided the withholding agent with information about the NFFE’s substantial United States owners. Temporary regulations in TD 9657 revise and refine final FATCA regulations, TD 9610, and provide guidance to persons making certain U.S. related payments to FFIs and NFFEs, and payments by FFIs to other persons. The text of the temporary regulations also serves as the text of these proposed regulations.

REG–134361–12, page 895. Payors of payments of certain U.S. source income to foreign persons are subject to comprehensive payee documentation, information reporting, and tax withholding requirements under sections 1441, 1442, and 1443 (contained in chapter 3 of subtitle A of the Internal Revenue Code). These payments may also be subject to comprehensive payee due diligence and documentation, information reporting, and tax withholding rules under chapter 4 (sections 1471–1474), Chapter 61, and section 3406. Temporary regulations in TD 9658 provide guidance coordinating and conforming the due diligence, information reporting, and tax withholding rules under chapter 3 and 61 and section 3406 with the requirements under chapter 4. The text of the temporary regulations also serves as the text of these proposed regulations.

Finding Lists begin on page ii. Index for July through March begins on page iv.