Bilateral Agreement Alternative to FATCA Implementation Brings New Twist to International Tax Cooperation

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Sunday, April 1, 2012
Author: 
Bruce Zagaris
Volume: 
28
Issue: 
4
Abstract: 
On the evening of February 8, 2012, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations on the Foreign Account Taxpayers Compliance Act[1] and a joint statement regarding an intergovernmental approach with five major trading partners of the U.S. with respect to improving international tax compliance and implementing FATCA (hereafter the Joint Statement).[2] This article discusses some of the policy issues surrounding the Joint Statement. [1]               U.S. Department of Treasury, Regulations Relating to Information Reporting by Foreign Financial Institutions and Withholding on Certain Payments to Foreign Financial Institutions and Other Foreign Entities, REG-121647-10, Feb. 8, 2012.   [2]               U.S. Department of Treasury, Joint Statement regarding an Intergovernmental Approach to Improving International Tax Compliance and Implementing FATCA, Feb. 8, 2012.