Friday, May 2, 2014

IRS Announces That Tax Rules for Overseas Banks Will See Light Enforcement In the Next 2 Years!

IRS Notice 2014-33 announces that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration with respect to the implementation of FATCA by withholding agents, foreign financial institutions (FFIs), and other entities with chapter 4 responsibilities, and with respect to certain related due diligence and withholding provisions under chapters 3 and 61, and section 3406.

This notice also announces certain intended amendments to the regulations under sections 1441, 1442, 1471, and 1472, including amendments providing that a withholding agent or FFI may treat an obligation (which includes an account) held by an entity that is opened, executed, or issued on or after July 1, 2014, and before January 1, 2015, as a preexisting obligation for purposes of sections 1471 and 1472, subject to certain modifications set out in the notice. 

Taxpayers may rely on Notice 2014-33 regarding these proposed amendments to the regulations prior to their issuance.

Notice 2014-33 will be published in Internal Revenue Bulletin 2014-21 on May 19, 2014.

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Notice 2014-33

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