The IRS today released an advance version of Notice 2016-08 announcing an intention to amend provisions of the regulations under chapter 3 (sections 1441-1464) and chapter 4 (sections 1471-1474). An IRS transmittal message explains that Notice 2016-08:
According to Notice 2016-08 [PDF 46 KB], these changes will “ease burdens on FFIs” and also respond to comments concerning certain aspects of the regulations. The IRS notice provides that taxpayers may rely on today’s guidance prior to the issuance of amended regulations.
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