The Internal Revenue Service and the Department of Treasury are moving ahead with new rules that will greatly expand the reporting and disclosure requirements for payments made to foreign financial institutions—but they are also taking unusual steps to solicit public comment on the new rules along the way.
The request for comment is the first formal communication from the IRS to taxpayers since Congress passed the Hiring Incentives to Restore Employment Act on March 18. The HIRE Act includes a provision titled the Foreign Account Tax Compliance Act (FACTA), aimed at finding offshore accounts used to shelter income from U.S. tax. ...