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Abstract
On March 18, 2010, President Obama signed Chapter 4 of the Public Law 111-147 into law, otherwise known as the HIRE Act. Section 511(a) of Part II under Title V, Subtitle A of the HIRE Act added Section 6038D, Information with Respect to Foreign Financial Assets to the Internal Revenue Code. Section 6038D requires US taxpayers to report ownership of specified foreign financial assets with their US income tax returns, to the extent the total value of those assets exceeds certain threshold amounts. The IRS issued corresponding regulations in mid-December 2011 ; temporary regulations, T.D. 9567 and proposed regulations, REG-130302-10. The text of the temporary regulations serves as the text of the proposed regulations. The temporary regulations provide guidance to individuals who are required to report their interest in foreign financial assets and the proposed regulations will apply to specified domestic entities when they are required to report their interest in foreign financial assets beginning in 2012. The IRS is expected to issue final regulations on or before December 31, 2012.