International

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Final Regulations Under FATCA Address Phased-In Due Diligence, IGAs, Compliance Obligations and More (TDNR TG-1825; T.D. 9610)

The Treasury and IRS released long-awaited final regulations late on January 17 under the Foreign Account and Tax Compliance Act (FATCA), enacted as part of the Hiring Incentives to Restore Employment (HIRE) Act of 2010 (P.L. 111-147 ). FATCA targets noncompliance by U.S. taxpayers using foreign accounts, the Treasury said in a news release.

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Chief Counsel Recommends Nonacquiescence in U.G. Patel (AOD-2012-05)

IRS Chief Counsel has recommended nonacquiescence to the Tax Court’s decision in U.G. Patel, 138 TC—, No. 23, Dec. 59,100 . Chief Counsel disagrees with the court’s conclusion that the uncertain state of the law is a factor that supports a finding of reasonable cause and good faith, without any consideration of a taxpayer’s investigation of the contemporaneous state of the law, including the failure to obtain competent professional advice.

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Kansas ~ Personal Income, Sales and Use Taxes: Governor Expresses Tax Goals in State of the State Address; FY 2014 Budget Report Released

Gov. Sam Brownback set forth his goals for Kansas related to personal income taxes and sales and use taxes in his State of the State address delivered on January 15, 2013. The governor’s proposed tax plan includes reducing the state’s bottom rate of 3.0% to 2.5% in tax year 2014 and then to 1.9% in tax year 2016.

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New Jersey ~ Unclaimed Property: U.S. Supreme Court Will Not Review Travelers’ Cheques Law Change

A corporation that engaged in travel-related services has been denied U.S. Supreme Court review of whether New Jersey’s retroactive shortening from 15 years to three years of the period after which not-yet-used travelers’ cheques are presumed abandoned violates the federal Due Process Clause by allowing the state to confiscate the proceeds of private enterprise under an arbitrary and unreasonable presumption of abandonment. The corporation also had challenged the law change on the basis that it effected an unconstitutional taking.

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Individual Not Liable for Accuracy-Related Penalties; Taxpayer Had Reasonable Cause for Failure to Report IMF Wages as Self-Employment Income (Chien, TCM)

An individual who was hired by the International Monetary Fund (IMF) was not liable for accuracy-related penalties. She had reasonable cause for her failure to report her IMF wages as self-employment income. She self-prepared the tax returns at issue and reported her IMF wages as income;

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