Definitions, Scope, Carveouts Initial Focus Under FATCA, DiFronzo Says

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Guidance on broad new requirements that foreign financial institutions report accounts with U.S.-owned assets to U.S. tax authorities is likely to focus first on carveouts and issues of definition and scope, says Mike DiFronzo, IRS deputy associate chief counsel, international (technical). Di Fronzo tells a tax forum sponsored by BNA Tax & Accounting and hosted by Buchanan, Ingersoll, and Rooney PC that the government is actively seeking comments as part of its effort to issue guidance as quickly as possible.