IRS Tasked With Determining Good-Faith FATCA Compliance

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Determining whether taxpayers have made a good-faith effort to comply with the Foreign Account Tax Compliance Act under new guidance rests largely with the Internal Revenue Service, a Treasury Department official said.
Julia Tonkovich of Treasury's Office of International Tax Counsel said the IRS will have most of that task under Notice 2014-33, which provides a two-year period of light enforcement if taxpayers make such an effort (86 DTR G-4, 5/5/14)
“It's always a good idea to have practices and procedures written down, so you can look to those procedures if you're ever asked a question about compliance,” she said at the May meeting of the American Bar Association Section of Taxation.