Guidance Issued on Information Reporting by Domestic Entities Under Code Sec. 6038D with Respect to Specified Foreign Financial Assets (Notice 2013-10)

Guidance has been issued concerning the first tax year certain domestic entities will be required to report interests in specified foreign financial assets under Code Sec. 6038D . Proposed Reg. §1.6038D-6 , which applies to tax years beginning after December 31, 2011, sets out the conditions under which a domestic entity will be considered a specified domestic entity and, therefore, required to report specified foreign financial assets in which the entity holds an interest. The IRS and the Treasury Department intend that, when final regulations are issued under Code Sec. 6038D , those final regulations will modify the effective/applicability date of Proposed Reg. §1.6038D-6 . Reporting by domestic entities of interests in specified foreign financial assets will not be required before the date specified by final regulations, which will not be earlier than tax years beginning after December 31, 2012.

 

Notice 2013-10, 2013FED ¶46,254

 

Other References:

 

Code Sec. 6038D

 

CCH Reference – 2013FED ¶35,598.35

 

Tax Research Consultant

CCH Reference – TRC FILEBUS: 9,108

 

AUTHOR

Wolters Kluwer Tax and Accounting

Wolters Kluwer Tax and Accounting is a leading provider of software solutions and local expertise that helps tax, accounting, and audit professionals research and navigate complex regulations, comply with legislation, manage their businesses and advise clients with speed, accuracy and efficiency. Wolters Kluwer Tax and Accounting is part of Wolters Kluwer N.V. (AEX: WKL), a global leader in information services and solutions for professionals in the health, tax and accounting, risk and compliance, finance and legal sectors. We help our customers make critical decisions every day by providing expert solutions that combine deep domain knowledge with specialized technology and services. Wolters Kluwer reported 2016 annual revenues of €4.3 billion. The company, headquartered in Alphen aan den Rijn, the Netherlands, serves customers in over 180 countries, maintains operations in over 40 countries and employs 19,000 people worldwide. Wolters Kluwer shares are listed on Euronext Amsterdam (WKL) and are included in the AEX and Euronext 100 indices. Wolters Kluwer has a sponsored Level 1 American Depositary Receipt program. The ADRs are traded on the over-the-counter market in the U.S. (WTKWY).

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