Government Looking at Partnership Issues Under FATCA, Plowgian Says

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The government is considering how best to address partnerships and other passthrough entities, among a host of other issues, under the disclosure regime established by the Foreign Account Tax Compliance Act, a Treasury Department official says. “We're thinking very hard about that,” Michael Plowgian, an attorney-adviser in Treasury's Office of Tax Policy, says. He adds that Treasury is looking at the possibility of a tracing regime or a possible “rough justice” approach that would look at the types of assets in a partnership in determining what would constitute a withholdable payment under FATCA. Plowgian says because of the way partnerships are structured, these entities represent a significant challenge as the government works to implement the statute.