This advisory discusses the IRS’ release of Notice 2014-33, setting out additional guidance on the implementation of the Foreign Account Tax Compliance Act. The notice also announces several amendments to the FATCA regulations, which are intended to facilitate compliance. Additionally, the advisory explains the IRS’ announcement of modifications and clarifications to be made to the “Killer B” regulations under Section 367(b), which reflects the IRS’ belief that taxpayers have been misinterpreting, if not exploiting, the Killer B regulations in ways that are inconsistent with their policy.
The advisory is provided in PDF on the Alston & Bird website: www.alston.com/advisories/intl-tax-may-2014
Written by Edward Tanenbaum, Partner, Federal & International Tax | Alston & Bird LLP