Analysing the protocol to tax FATCA derivative transactions

September 11 2012

Erica Gut and David Balaban of PwC analyse the International Swaps and Derivatives Association's (ISDA) recently released protocol to deal with a provision in FATCA that could subject derivative transactions to a 30% withholding tax on certain US-sourced payments.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

‘TP is a team sport’: NRF’s new hire on practice-building

Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says

Sam Sholli, June 04 2026

Direct Tax

International law firm launches with tax as key focus

Mada has opened simultaneously in Paris and Dubai with an eight-lawyer team from Trinity International

Tom Baker, June 03 2026

Indirect Tax

This month in indirect tax: Fonoa acquires PwC indirect tax tech platform

PwC will continue to provide indirect tax services as part of the deal; in other news, the CJEU addressed the VAT treatment of TP adjustments

Tom Baker, June 03 2026

Direct Tax

Gateley Middle East hires head of tax alongside eight-strong team

The arrival of Renan Ozturk and his team from A&M Tax introduces a unique proposition within the Middle East legal market, the firm said

Sam Sholli, June 02 2026

Direct Tax

Ryan continues European expansion with Svalner Atlas buyout

The deal, reportedly worth $400m, will add Svalner Atlas’s 50-partner Nordic and Benelux presence to Ryan’s rapidly growing global footprint

Sam Sholli, June 01 2026

Direct Tax

Winston Taylor merger closes to form £1.23bn transatlantic firm

The combined firm, which comprises over 1,400 lawyers, will boast robust tax practices in both the UK and US

Sukanya Sarkar, June 01 2026

Direct Tax

ITR’s Italy report: advisers jostling for position in ‘distinctly pluralistic’ market

Cascading tax reform, bullish foreign investment and vigorous TP audits have made Italy’s tax advisory market dynamic and stiffly competitive

Sam Sholli, June 01 2026

Direct Tax

A taxing week: Tax firms can’t afford to ignore increased private client demand

As ITR data reveals that 2025 saw more than double the amount of private client hires than 2024, it seems firms are jostling for position

Sam Sholli, May 29 2026

Direct Tax

This week in tax: Amazon’s UK tax bill tops £1bn

The US multinational paid 20% more tax in 2025 than 2024, it said; in other news, more than 25,000 HMRC staff have been upskilled on AI

Tom Baker, May 29 2026

Direct Tax

Pillar two presenting ‘culture change’ challenges in Asia-Pacific: KPMG policy leaders

Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard

Sam Sholli, May 28 2026