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By Benjamin Tolub*
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations on February 8, 2012, moving forward towards the implementation of the Foreign Account Tax Compliance Act (FATCA). The proposed regulations phase in the implementation of FATCA further and relax some of the rules, responding to the comments of the financial community. Treasury and IRS tried to take into account the comments provided on the FATCA Notices and tried to leave enough time to foreign financial institutions (FFIs) to implement FATCA.
Among other types of FFIs, investment funds, banks, and insurance companies should particularly take FATCA into...
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