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…

BNA INSIGHTS: When the Other Shoe Falls: IRS Notice 2010-46 Restricts the Application of Notice 97-66 for Cross-Border Securities Loans

Notice 97-66 created an opportunity for non-U.S. financial institutions to participate in the securities lending markets for stocks of U.S. corporations without suffering…

IRS Withdraws Guidance Implementing Cross-Border Securities Transaction Rules

The Internal Revenue Service May 20 issued Notice 2010-46, withdrawing 1997 guidance that generally limited the aggregate U.S. gross basis tax on a series of securities lending…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

American Institute of Certified Public Accountants Offers Comments to Treasury, IRS on Foreign Bank Account Report Guidance

The American Institute of Certified Public Accountants May 17 unveiled comments on requirements for taxpayers required to file the Report of Foreign Bank Account (FBAR) …

Pace of Change in Cross-Border Transparency Initiatives Increasing, IRS Official Says

The pace of change in the new world of increased transparency and information exchange has “accelerated on all fronts,” Internal Revenue Service Deputy Associate Chief Counsel (International) Theodore…

ANALYSIS: HIRE Act Change Suspends Limitations When Taxpayers Fail to Report International Transactions

A recent amendment to Section 6501(c)(8) has the sweeping effect of keeping the statute of limitations open for all issues on a taxpayer’s return if it fails to report international transactions on…

Significant Number of Offshore Asset Cases to be Done by End of Year, IRS Officials Say

The Internal Revenue Service has assigned cases to agents for nearly all of the 15,000 taxpayers who came in under the special program to allow voluntary disclosures of offshore assets that…

IRS Counsel Says Information Reporting Regimes Will Alter Tax Administration

The Internal Revenue Service’s “enhanced information reporting” initiatives coupled with the onset of tax return preparer regulations will transform aspects of tax administration…

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…

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