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The international section of IRS's 2009-2010 priority guidance plan is likely to be “a little less ambitious” than in previous years, but it is expected to focus significant attention on offshore compliance, tax evasion, and withholding, says Michael DiFronzo, IRS deputy associate chief counsel (international-technical). While not saying specifically what would be on the plan, DiFronzo notes IRS's ongoing emphasis on changes to the qualified intermediary agreement and on modifying cross-border withholding and reporting requirements. He said the business plan is expected within “a matter of weeks.” Tax officials are looking at issuing guidance on a number of remaining questions raised by the enactment of tax code Section 108(i), following the August issuance of a revenue procedure on the section, says Steven Frost, a senior counsel at Treasury.
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