US Withholding Tax Practical Implications of QI and FATCA

The US QI and FATCA regulations came into being in 2001 and 2010 respectively. They remain today the most challenging cross border tax regulations for financial institutions to comply with and operationalise. There is an increasing trend for financial ins

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ROSS MCGILL Second Edition

GLOBAL FINANCIAL MARKETS

Global Financial Markets

Global Financial Markets is a series of practical guides to the latest financial market tools, techniques and strategies. Written for practitioners across a range of disciplines it provides comprehensive but practical coverage of key topics in finance covering strategy, markets, financial products, tools and techniques and their implementation. This series will appeal to a broad readership, from new entrants to experienced practitioners across the financial services industry, including areas such as institutional investment; financial derivatives; investment strategy; private banking; risk management; corporate finance and M&A, financial accounting and governance, and many more. More information about this series at http://www.palgrave.com/gp/series/15011

Ross McGill

US Withholding Tax Practical Implications of QI and FATCA Second Edition 2019

Ross McGill TConsult Ltd Yateley, Hampshire, UK

Global Financial Markets ISBN 978-3-030-23084-5    ISBN 978-3-030-23085-2 (eBook) https://doi.org/10.1007/978-3-030-23085-2 © The Editor(s) (if applicable) and The Author(s), under exclusive licence to Springer Nature Switzerland AG 2013, 2019 This work is subject to copyright. All rights are solely and exclusively licensed by the Publisher, whether the whole or part of the material is concerned, specifically the rights of translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. The publisher, the authors and the editors are safe to assume that the advice and information in this book are believed to be true and accurate at the date of publication. Neither the publisher nor the authors or the editors give a warranty, express or implied, with respect to the material contained herein or for any errors or omissions that may have been made. The publisher remains neutral with regard to jurisdictional claims in published maps and institutional affiliations. This Palgrave Macmillan imprint is published by the registered company Springer Nature Switzerland AG. The registered company address is: Gewerbestrasse 11, 6330 Cham, Switzerland

Foreword

The first edition of this book was hailed across the industry because of its clarity and consistency in explaining a very complex subject. This second edition has continued that tradition and includes now additional diagrammatic descriptions as well as new topics such as Code 871(m) in Part I and intergovernmental agreements (IGAs) in Part II that were either in their infancy or non-existen