FATCA Compliance Uncertainties Keep Lawyers Up At Night

By Matthew Villmer (November 19, 2013, 6:15 PM EST) -- With the Foreign Account Tax Compliance Act taking full effect in July, investors across the globe are concerned about the U.S. government's silence on whether it will seek criminal prosecution for violators and how the Internal Revenue Service plans to regulate foreign-to-foreign transactions.

The current lack of guidance from U.S. regulators and the IRS is forcing tax practitioners to fill the void by providing clients with best- and worst-case scenarios.

"I've had numerous calls about FATCA because it's difficult for people to understand why the information requested is any of the IRS's business," said John Taylor, a U.S. tax partner in...

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