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ARTICLE · 05 JANUARY 2012

Further Reporting Required This Year By U.S. Individuals Who Own Foreign Assets

Davies Ward Phillips & Vineberg LLP
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Section 511 of the Hiring Incentives to Restore Employment (HIRE) Act added Section 6038D to the Internal Revenue Code, which imposes new reporting requirements on a U.S. individual whose ownership interests in specified foreign financial assets exceed $50,000.

CanadaTax
Abraham Leitner
Abraham Leitner
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Section 511 of the Hiring Incentives to Restore Employment (HIRE) Act added Section 6038D to the Internal Revenue Code, which imposes new reporting requirements on a U.S. individual whose ownership interests in specified foreign financial assets exceed $50,000. Section 6038D is effective for taxable years beginning after March 18, 2010; thus, for calendar-year taxpayers, 2011 is the first year for which the new rules are in effect. On December 19, the IRS published temporary regulations implementing the new reporting requirements. These rules are in addition to the longstanding foreign bank account (FBAR) reporting requirements, which also apply to some of the same foreign assets, and taxpayers who comply with the new rules will not be excused from filing FBARs for the same assets. Following are some highlights of the new reporting requirements.

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