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

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…

Leeway Urged for Some Foreign Payments under Generator Rules

Loss sharing or joint tax settlements permitted under foreign law should not automatically result in foreign payments being considered “noncompulsory” under rules to crack down on deals to…

Congress Aware of Issues That Surround Statute of Limitations Provision, Aide Says

Members of Congress are aware of the issues surrounding a controversial provision on the statute of limitations in legislation to require broad new reporting by foreign banks, a lawyer on…

New Law Could Prevent Closing out Reserves for Some Tax Positions, Practitioners Fear

A new tax law seemingly intended to apply only to the statute of limitations for assessments on foreign information filed with the Internal Revenue Service could force financial statement preparers…

Guidance on Definitions, Scope, Carveouts Initial Focus under New Foreign Account Tax Compliance Act, IRS Official Says

Guidance on broad new requirements that foreign financial institutions report accounts with U.S.-owned assets to U.S. tax authorities is likely to focus first on carveouts and…

Foreign Accounting Tax Compliance Act’s 2013 Effective Date Due to Consideration of Foreign Law, JCT Staffer Says

The application of foreign law was a consideration when drafting the Foreign Accounting Tax Compliance Act, which contains a reasonable period of time for compliance on the part of…

IRS International Enforcement Extends to Many Cases Where No Tax Due, Practitioner Cautions

Taxpayers should be aware that the Internal Revenue Service’s intense focus on international tax compliance applies in many cases where tax is not due, a Sullivan & Worcester practitioner said April 28…

IRS Focused on Timelines, Burdens in Implementing Foreign Accounting Tax Compliance Act Provisions, Top Official Says

Internal Revenue Service Associate Chief Counsel (International) Steven Musher April 26 said the agency remains focused on timelines and on imposing the least possible burden on taxpayers as it works to implement comprehensive…

IRS Looking at Buy-In Issue Surrounding Cost-Sharing Arrangements, Official Says

The Internal Revenue Service is “affirmatively looking” at the buy-in issue for cost-sharing arrangements in the transfer pricing context, Large and…

Administration Continues to Back Stand-Alone Use of International Tax Provisions, Senior Treasury Official Says

The administration continues to support the use of international tax proposals from its fiscal year 2011 budget as stand-alone provisions should Congress be inclined to do so, a senior Treasury…

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