On December 14, 2011, the Internal Revenue Service ("IRS") issued temporary and proposed regulations in a Notice of Proposed Rulemaking relating to provisions that require foreign financial assets to be reported to the IRS for tax years beginning after March 18, 2010.

The Foreign Account Tax Compliance Act ("FATCA"), enacted in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act, requires certain U.S. taxpayers holding foreign financial assets with an aggregate value exceeding either $50,000 on the last day of the taxable year or $75,000 at any time during the taxable year to report certain information about those assets on a new form -- Form 8938 - Statement of Foreign Financial Assets.

Married individuals filing a joint annual return are not required to file Form 8938 unless the aggregate value of all of the specified foreign financial assets in which either spouse has an interest exceeds $100,000 on the last day of the taxable year or $150,000 at any time during the taxable year.