Governments have bridled at its extra-territorial effect, financial institutions have laboured to comply with its reporting and due diligence requirements, and some US Congressmen threatened to wreck it, but the withholding requirements under the Foreign Account Tax Compliance Act (FATCA) still took effect on July 1, six months later than planned.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap