On December 15, Internal Revenue Service Commissioner Douglas Shulman announced that new proposed regulations under the Foreign Account Tax Compliance Act ("FATCA") will be released "soon after the new year." The Commissioner indicated that these regulations will provide guidance to address concerns that have been raised regarding the implementation of the requirements under FATCA.

FATCA which was enacted in 2010, targets non-compliant U.S. taxpayers with foreign accounts. Additionally, it requires foreign financial institutions to report to the IRS information about financial accounts held by U.S. taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest. Failure to meet these reporting requirements could result in a 30 percent withholding tax.