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
Code Sec. 6038D
CCH Reference – 2013FED ¶35,598.35
Tax Research Consultant
CCH Reference – TRC FILEBUS: 9,108