IRS Issues Proposed Regulations on the Foreign Account Tax Compliance Act
By ANDREW M. SHORT, DAVID MAKSO & MELVIN M. PERALTA
The IRS recently released proposed regulations providing much needed guidance on the Foreign Account Tax Compliance Act (FATCA). The proposed regulations modify and supplement initial guidance published by the IRS and Treasury over the past two years. Although the proposed regulations mark a significant milestone in the development of FATCA, many issues remain unresolved and final regulations are expected later this year. In addition, this alert describes an intergovernmental framework proposed by the United States, France, Germany, Italy, Spain, and the United Kingdom for implementing FATCA.