SIFMA provides supplemental comments to the U.S. Treasury and the Internal Revenue Service (IRS) on the final regulations implementing the provisions of the Foreign Account Tax Compliance Act (FATCA) that were included in section 501 of the Hiring Incentives to Restore Employment Act (HIRE Act).

SIFMA expands on three specific issues mentioned in SIFMA’s preliminary comments filed on June 21, 2013:

• The “reason to know” standard is excessively broad and should be substantially revised or its implementation delayed;
• Further clarification should be provided regarding reliance on documentation collected by or certifications provided by other persons and the rules regarding electronic transmissions should be relaxed and expanded; and</li>
• The “eyeball” test and documentary evidence for preexisting and new obligations.

SIFMA’s Preliminary Comments on FATCA (June 21, 2013)