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Expert Analysis

2 International Tax Developments You Should Know About

Law360, New York (May 19, 2015, 3:52 PM EDT) -- In Notice 2015-10, the IRS announced that it and the Treasury will issue regulations to limit credits or refunds for certain withholding taxes to the amount actually deposited by withholding agents. The regulations would apply to withholding on foreign persons under Sections 1441 through 1443 (Chapter 3) and under Sections 1471 and 1472 (Chapter 4, also known as the Foreign Account Tax Compliance Act). The hope is that this "deposit limitation" will lessen the Treasury's financial risk of crediting or refunding more tax, based on Form 1042-S reporting, than it collects or can collect....

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