Members Marianna G. Dyson and Michael M. Lloyd Author FATCA Treatise


Washington, D.C., October 1, 2015 -- Miller & Chevalier Chartered is pleased to announce the publication of U.S. Information Reporting and Withholding at the Source -- FATCA by Marianna G. Dyson, firm Member and Chair of the firm's Employee Benefits department, and Member Michael M. Lloyd. This portion of their forthcoming comprehensive treatise on information reporting and withholding addresses the Foreign Account Tax Compliance Act (FATCA) and was published by Thomson Reuters Checkpoint. A summary report, available here, explains the dividend and income reporting requirements for banks, brokerages and other financial institutions under FATCA.

The report provides a broad analysis of FATCA, which was enacted in 2010 to prevent offshore tax evasion by U.S. citizens and residents. Beginning earlier this year, FATCA requires foreign financial institutions (FFIs) and other financial intermediaries to file reports with the Internal Revenue Service (IRS) on the accounts of their U.S. clients with balances over $50,000. FFIs that fail to comply are subject to a 30 percent withholding tax and could be restricted from participating in U.S. capital markets.

"FATCA is a new and unique body of law and, while its obligations appear simple, they can be quite complex and expensive to meet," Lloyd said. "This report provides guidance to help professionals and their clients meet FATCA's requirements and manage the related risks and costs."

The report examines the steps FFIs must take to enter into a FATCA agreement with the IRS. It also outlines the application of FATCA's rules for non-financial foreign entities and U.S. withholding agents to ensure compliance.

About Thomson Reuters and Thomson Reuters Checkpoint

Thomson Reuters is a leading source of information for businesses and professionals. It combines industry experience with innovative technology to deliver critical information to leading decision makers in the financial and risk, legal, tax and accounting, intellectual property and science and media markets, powered by one of the world's largest news organization. For more information, go to

Thomson Reuters Checkpoint provides integrated research, editorial insight, productivity tools, online learning and news updates along with links to related content and software. It is relied on by thousands of tax and accounting professionals, including practitioners in 97 of the Top 100 U.S. law firms, 99 of the Fortune 100 companies and all of the top 100 U.S. CPA firms.

About Miller & Chevalier

Founded in 1920, Miller & Chevalier is a Washington, DC law firm with a global perspective and leading practices in Tax, Employee Benefits (including ERISA), International Law and Business, White Collar and Internal Investigations, Complex Litigation, and Government Affairs. In an era of big law, Miller & Chevalier is a top-ranked firm sharply focused on targeted areas that interact with the federal government. Over the past three years, the firm's lawyers have represented more than 40 percent of the Fortune 100, one-quarter of the Fortune 500 and approximately 30 percent of the Global 100. Based in Washington, DC, a significant number of firm lawyers have held senior positions in the U.S. government and have written many of the regulations they currently help clients navigate. For more information on the firm, visit


Laura Miller, Media Relations, Greentarget, 312-252-4104

Related Files
Related Links