Every professional trustee who manages or administers funds that invest in US securities or have US beneficiaries will be affected by the proposed Foreign Account Tax Compliance Act (FATCA) regime. Foreign financial institutions (FFIs) must be prepared to register and participate, or suffer withholding on all US source income and gross proceeds. Non-financial foreign entities (NFFEs) must be prepared to disclose US owners or suffer withholding on all US source income and gross proceeds.
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