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Law360 (April 16, 2020, 5:52 PM EDT) -- The Internal Revenue Service announced Thursday it had extended by three months the deadline for countries to submit financial information under the Foreign Account Tax Compliance Act, to the end of 2020.
The extension applies to countries that have signed information-sharing agreements with the U.S. under the law, which requires financial institutions to report data such as the identity, address and balance of U.S. account-holders to the U.S. competent authority, or face withholding penalties for U.S. currencies or bonds. The IRS said it was extending the deadline for Model 1GA jurisdictions due to the coronavirus outbreak.
The commissioner of the IRS Large Business & International Division, Doug O'Donnell, said in a Tuesday memo that the department would continue to initiate new examinations under FATCA, while suspending them for most other areas while the national state of emergency persisted. The IRS will also begin new exams under its Compliance Assurance Process program, in which a taxpayer elects to be audited in real-time throughout the year, and for the Large Corporate Compliance program, which selects cases for the largest and most complex companies.
Both programs restarted last year, following agency overhauls.
O'Donnell also said the division would review most of its "campaigns," or issue-specific enforcement efforts aimed at medium-size taxpayers. But it would continue campaigns on microcaptive insurance, syndicated conservation easements, repatriation and other issues related to the 2017 Tax Cuts and Jobs Act,
the memo stated.The agency would also continue proceedings voluntarily initiated by taxpayers, such as pre-filing agreements or refund claims.
All of these examinations and enforcement efforts would be done without in-person contact, according to LB&I.
"While we cannot anticipate and provide guidelines for every possible situation, it remains vitally important for all LB&I employees to be sensitive to the individual circumstances of taxpayers and provide them with the appropriate tax administrative actions commensurate with the taxpayer's situation," O'Donnell said.
The agency did not respond to requests for further comment.
--Editing by Vincent Sherry.
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