The Foreign Account Tax Compliance Act (FATCA) would impose a 30% withholding on most interest and dividends paid by US payors to non-US retirement plan funds beginning January 1, 2014, unless such non-US plans are exempt under US Treasury regulations or are specifically listed in an Intergovernmental Agreement (IGA) entered into between the US and the other country.

There have been a number of recent developments worth noting for non-US retirement plans, including a 6-month delay in the imposition of the tax, a new draft form for seeking an exemption, and new IGA listings of exempt plans for Spain and Germany. Our review of the current status of the impact of FATCA on non-US retirement plans can be found in the attached memo.


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