On May 12, 2014 the IRS published in the IRB its April 21st technical corrections relating to brokers making certain returns of information with respect to their customers as per the final and temporary regulations that relate to the withholding of tax on certain U.S. source income paid to foreign persons, information reporting and backup withholding with respect to payments made to certain U.S. persons, portfolio interest paid to nonresident alien individuals and foreign corporations, and the associated requirements governing collection, refunds, and credits of withheld amounts under these rules. See my February 21, 2014 article analyzing these substantial amendments to the FATCA regulations.
Need for Correction
The technical corrections contain amendments to §1.6045–1T. This regulation affects persons that are brokers making certain returns of information with respect to their customers. See the Technical Corrections at Announcement 2014–21 (Internal Revenue Bulletin 2014-20) May 12, 2014
As published, the temporary regulation contains errors in the instructions that need to be corrected. First, the instructions indicate that § 1.6045–1T is amended. However, the temporary regulation is added, not amended. Second, the instructions do not add paragraphs (m) through (o), which should be included in the temporary regulation by cross-reference to the final regulation. The correcting amendments add the temporary regulation, including paragraphs (m) through (o).
Relevant excerpts at http://wp.me/pA2Cl-Xd
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