The Foreign Account Tax Compliance Act’s (FATCA) withholding provisions are found in Internal Revenue Code Sections 1471-1472,1 enacted under the Hiring Incentives to Restore Employment Act, which was signed into law on March 18, 2010.2 These provisions are intended to strengthen the U.S. voluntary compliance tax system and prevent tax evasion by U.S. taxpayers who directly or indirectly, for example, through foreign entities, maintain foreign accounts. FATCA does ...

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