International Tax
Our team is highly experienced in U.S. federal income tax matters concerning both domestic taxpayers engaged in foreign activities and foreign entities operating within the United States. With a client base spanning the globe, our firm serves individuals and corporations with unparalleled proficiency in international tax matters.
We advise on optimizing tax benefits for our clients, leveraging our deep understanding of U.S. and foreign tax regulations, FATCA compliance and reporting rules, and tax treaties to provide tailored solutions that mitigate tax liabilities globally.
In addition to tax optimization, Basswood offers strategic counsel on a wide range of multinational transactions, including mergers and acquisitions, joint ventures, and restructurings. Drawing on our global perspective and extensive experience, we assist clients in navigating the intricacies of cross-border business dealings, including FATCA and other U.S. withholding and reporting regimes, while minimizing tax exposure. We develop legal structures that effectively reduce tax burdens, whether through the use of intermediate holding companies, tax-haven jurisdictions, or other strategic arrangements tailored to each client’s unique needs and objectives.
FATCA Model 2 Reporting
The U.S. Foreign Account Tax Compliance Act (FATCA) requires Foreign Financial Institutions (FFIs) to identify and report information regarding U.S. account holders to the Internal Revenue Service. For institutions operating under Model 2 Intergovernmental Agreements, this reporting occurs directly to the IRS, alongside strict registration, due-diligence, and annual certification obligations.
Basswood Counsel assists investment entities operating under Model 2 IGAs in meeting these requirements with precision and efficiency. We manage the full FATCA lifecycle—from initial registration and GIIN maintenance to annual reporting and procedural reviews—ensuring our clients satisfy their obligations with clarity and confidence.
Our approach streamlines Model 2 FATCA compliance for investment funds and related structures, reducing administrative burdens, minimizing errors, and facilitating coordinated reporting across jurisdictions. With a disciplined workflow and direct engagement with the IRS FATCA systems, we enable fund managers and administrators to maintain focus on their core responsibilities while preserving full compliance.