S&C Lawyers Co-Author Article on IRS and Treasury Department Proposed Phase-In FATCA Requirements

Fall 2011
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Mr. Solomon, Ms. Fiorini and Mr. Orchowski co-authored an article titled,“IRS and Treasury Department Propose Phase-In FATCA Requirements” in the Fall 2011 issue of the Journal of Taxation of Investments. The article discussed Notice 2011-53, which announced a proposal by the Treasury Department and the IRS to implement a revised schedule providing timing relief to financial institutions and other parties that will need to comply with the international tax enforcement related (FATCA) provisions of the HIRE Act. The notice outlined a phased implementation timeline, extending certain FATCA-related deadlines beyond the January 1, 2013, effective date provided by the statute. These revisions were precipitated by discussions with financial institutions and foreign governments who expressed concern over the administrative and legal challenges presented by FATCA.