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IRS Hoping to Address Many Issues in First Guidance Under Foreign Account Tax Compliance Act

June 4, 2010 in Daily Tax Report · Leave a Comment 

Internal Revenue Service Associate Chief Counsel Steven Musher June 3 said his agency is planning to include as many issues as it can in the first wave of guidance on legislation requiring broad new reporting and disclosure from foreign banks about their U.S. account holders.

Speaking to the Federal Bar Association Section of Taxation at an insurance conference, Musher said IRS will address, “as far as we can,” the question of which classes of financial institutions will be required to disclose under the rules and which will be carved out.

In response to questions, the IRS official said it is too soon to say whether various types of insurance companies would be candidates for the latter category under the new law. The statute implemented the provisions of the Foreign Account Tax Compliance Act under the Hiring Incentives to Restore Employment (HIRE) Act (Pub. L. No. 111-147), signed into law March 18 (52 DTR GG-1, 3/19/10).

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