IRS Associate Chief Counsel Musher says his agency is planning to include as many issues as it can in the first wave of guidance on legislation requiring broad new reporting and disclosure from foreign banks about their U.S. account holders. Musher says IRS will address, “as far as we can,” the question of which classes of financial institutions will be required to disclose under the rules and which will be carved out. He says it is too soon to say whether various types of insurance companies would be candidates for the latter category under the new law. Meanwhile, Treasury Deputy Assistant Secretary for Tax Policy McMahon says that the administration is considering issuing formal guidance related to insurance companies' claims for dividends received deductions, which Treasury believes are often overstated.
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