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Dina Kapur Sanna co-authored an article in the September issue of Trusts & Trustees on new 2010 tax legislation targeting offshore financial service providers. The article looks at the foreign account tax compliance provisions of the Hiring Incentives to Restore Employment (HIRE) Act as they apply to foreign financial institutions with U.S. account holders or that are invested in the U.S. capital markets. These provisions impose expansive new reporting and compliance burdens on foreign financial institutions and other foreign persons, requiring them to identify and disclose U.S. account holders. Failure to do so could lead to a new 30 percent U.S. withholding tax regime with respect to any payment of U.S. source investment income or proceeds from the sale of equity or debt instruments of U.S. issuers.
