Daily Tax Update - June 24, 2014: Joint Committee on Taxation Describes Highways Tax Bill

Joint Committee on Taxation Describes Highways Tax Bill:  In JCX-75-14, the Joint Committee on Taxation (the JCT) describes the chairman’s mark of the Preserving America’s Transit and Highways Act of 2014, scheduled for markup by the Senate Committee on Finance on June 26, 2014.  The chairman’s mark includes several “pay-fors,” including a provision that would extend the statute of limitations for IRS assessments to six years for substantial understatements of income that result from overstatements of basis, which would effectively overturn the Supreme Court’s holding in Home Concrete & Supply, LLC. v. United States, 132 S. Ct. 1836 (2012).  The markup would also expand minimum distribution rules applicable to employer sponsored tax-favored retirements plans, e.g. 401(k) plans, and to individual retirement arrangements (IRAs).

FATCA Developments:

The Internal Revenue Service (IRS) issued Revenue Procedure 2014-38, updating the Model 2 FFI Agreement to reflect the two sets of temporary regulations issued by the IRS and the Treasury Department on February 20, 2014.  The regulations can be accessed via: T.D. 9657, 9658.

The Canadian Parliament passed the Economic Action Plan 2014 Act, No. 1, which among other things, implements the FATCA IGA reached between the U.S. and Canada. 

The Treasury Department has added Taiwan to its list of jurisdictions that have reached agreement in substance to enter into a Model 2 FATCA IGA.  The list of jurisdictions can be accessed here.