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IRS Issues Foreign Financial Account Reporting Guidance - Emil Estafanous, CPA : Emil Estafanous, CPA

IRS Issues Foreign Financial Account Reporting Guidance

The IRS released a second notice giving superintendence on several stating mandate underneath a Foreign Account Tax Compliance Act (FATCA, partial of P.L. 111-147) (Notice 2011-34). The notice responds to concerns lifted by commenters following a distribution final Aug of Notice 2010-60, that contained rough superintendence on doing of a FATCA rules.

FATCA stretched a information stating mandate for unfamiliar financial institutions with honour to certain United States accounts. It also imposed withholding, support and stating mandate with honour to certain payments done to certain unfamiliar entities.

Notice 2011-34 provides a procedures for participating unfamiliar financial institutions to follow in identifying U.S. accounts among their pre-existing particular accounts. It also defines what a pass-through remuneration is for FATCA functions and provides superintendence on self-denial on pass-through payments.

The notice also lists certain categories of unfamiliar financial institutions that will be deemed to be compliant. These embody certain internal banks and certain investment vehicles. However, to be deemed compliant, such unfamiliar financial institutions will have to request for deemed-compliant status, obtain a unfamiliar financial establishment marker number, and plead each 3 years to a IRS that they accommodate a mandate for such treatment.

The notice discusses unfamiliar financial institutions’ obligations to news U.S. accounts. It also addresses a diagnosis of competent intermediaries. Finally, a notice provides superintendence on a focus of Sec. 1471 to dependent groups of unfamiliar financial institutions.

About Emil Estafanous, CPA
Certified Public Accountant (CPA) Tax Professional committed in representing taxpayers and resolving their tax problems.

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