Client Alert
On February 8, 2012, the IRS released proposed regulations under Code §§ 1471-74 (generally referred to as the FATCA provisions). The proposed regulations clarify, expand, and relax the requirements of the earlier FATCA Notices. This Client Alert briefly summarizes the most significant changes.
On the same day, a joint statement was released by the United States, France, Germany, Italy, Spain, and the United Kingdom announcing an intent to explore a common approach to FATCA through automatic information exchange based upon information-exchange provisions in tax treaties. If such an approach is adopted, the United States would agree to waive some of the more onerous FATCA requirement