Titlebook: US Withholding Tax; Practical Implicatio Ross McGill Book 2019Latest edition The Editor(s) (if applicable) and The Author(s), under exclusi

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腐蝕

WAX

Documentatione. In my experience, those firms that either do not understand the documentary requirements of the regulations or choose to try to get around them with commercial expediencies generally fail not only evidential requirements but also withholding and reporting obligations.

hallow

outskirts

Control and Oversighte previous QI Agreement, this was achieved by means of an independent Agreed Upon Procedure (AUP). However, while retaining many key aspects of the AUP, this model was replaced in 2017 with a more robust and wide-ranging system.

華而不實

Penaltiesor’ to compliance. Unlike many other jurisdictions, I have not seen the Internal Revenue Service (IRS) publicly announce the application of penalties, which would serve as an additional deterrent in the form of reputational damage.

萬花筒

Issues for Non-qualified Intermediariesualified intermediaries (QIs); every other financial institution is an NQI. NQIs are also deemed by the US to be facilitators of tax evasion, which means that they are more rigorous disclosure obligations and risk of higher penalties for non-compliance. This chapter explains the most common issues faced by NQIs and also by QIs with NQI clients.

DEI

Principles of IRC Code Chapter 3In this chapter, I will look at the overarching principles of Code Chapter 3. Later chapters will deal with the granular aspects of meeting these regulatory obligations.

注入

Defraud