On January 17, 2013, the Internal Revenue Service published final regulations under the Foreign Account Tax Compliance Act (?FATCA?), which are effective immediately. Congress enacted FATCA in 2010 to make it more difficult for United States taxpayers to conceal assets held in offshore accounts. In order to discover information about offshore accounts, FATCA imposes significant reporting obligations on both non-U.S. foreign financial institutions (?FFIs?) and United States taxpayers holding foreign financial accounts. As discussed below, a non-U.S. retirement plan may be subject to…
