Daily Tax Update - February 5, 2014: US Signs FATCA Agreements with Canada, Hungary, Mauritius and Italy

U.S. SIGNS FATCA AGREEMENTS WITH CANADA, HUNGARY, MAURITIUS AND ITALY:  The United States and  Canada have signed an intergovernmental agreement to implement the Foreign Account Tax Compliance Act (“FATCA”). The Treasury Department also announced the U.S. has signed IGAs with Hungary, Italy and Mauritius.

Treasury Deputy Assistant Secretary for International Tax Affairs Robert Stack said, “FATCA implementation is critical to combatting international tax evasion and promoting transparency.  The agreements announced today clearly demonstrate the considerable international support behind FATCA and we are proud to lead the global charge on this pressing issue.”

The text of the Canada agreement can be accessed via: http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/FATCA-Agreement-Canada-2-5-2014.pdf.

The Hungary agreement can be accessed via: http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/FATCA-Agreement-Hungary-2-4-2014.pdf.

The agreement with Italy can be accessed via: http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/FATCA-Agreement-Italy-1-10-2014.pdf.

The Mauritius agreement can be accessed via: http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/FATCA-Agreement-Mauritius-12-27-2013.pdf.

MISCELLANEOUS GUIDANCE RELEASED:
Revenue Procedure 2014-20 provides a safe harbor under which the Internal Revenue Service will, under certain, defined circumstances, treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity that holds real property as indebtedness that is secured by real property for purposes of § 108(c)(3)(A) of the Internal Revenue Code.  This revenue procedure will assist taxpayers with so-called “mezzanine” financing in workouts and similar circumstances. 

TAX BILLS INTRODUCED FEBRUARY 4TH:

1.[113rd] H.R.3986 : To amend the Internal Revenue Code of 1986 to adjust the phaseout of the health insurance tax credit for geographic variations in the cost-of-living. Sponsor: Rep Thompson, Mike [CA-5] (introduced 2/4/2014)      Cosponsors (18) Committees: House Ways and Means Latest Major Action: 2/4/2014 Referred to House committee. Status: Referred to the House Committee on Ways and Means.


2. [113rd] H.R.3987 : To amend the Internal Revenue Code of 1986 to exclude from gross income any prizes or awards won in competition in the Olympic Games. Sponsor: Rep Farenthold, Blake [TX-27] (introduced 2/4/2014)      Cosponsors (2) Committees: House Ways and Means Latest Major Action: 2/4/2014 Referred to House committee. Status: Referred to the House Committee on Ways and Means.


3. [113rd] H.R.3989 : To amend the Internal Revenue Code of 1986 to allow individuals a deduction for amounts contributed to disaster savings accounts to help defray the cost of preparing their homes to withstand a disaster and to repair or replace property damaged or destroyed in a disaster. Sponsor: Rep Ross, Dennis A. [FL-15] (introduced 2/4/2014)      Cosponsors (None) Committees: House Ways and Means Latest Major Action: 2/4/2014 Referred to House committee. Status: Referred to the House Committee on Ways and Means.


4. [113rd] S.1991 : A bill to amend the Internal Revenue Code of 1986 to allow individuals a deduction for amounts contributed to disaster savings accounts to help defray the cost of preparing their homes to withstand a disaster and to repair or replace property damaged or destroyed in a disaster. Sponsor: Sen Inhofe, James M. [OK] (introduced 2/4/2014)      Cosponsors (None) Committees: Senate Finance Latest Major Action: 2/4/2014 Referred to Senate committee. Status: Read twice and referred to the Committee on Finance.