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  1. Look at Tax Notes Today, 2010 TNT 177-3.

    The announcement was made in a webcast. From the article:

    John C. McDougal, Office of Chief Counsel, Small Business/Self Employed Division, said on an American Law Institute-American Bar Association webcast that investments in foreign mutual funds, which are PFIC investments, “have turned up in a large number of voluntary disclosures that we’re processing — many more than we anticipated, many more than I think tax practitioners anticipated.”

    Let’s hope the IRS chooses to put this on soon.

    There is a distressing tendency at the IRS to play hide the ball. For example, the offshore amnesty program was originally supposed to be secret, and was publicized only after an inadvertent leak of the internal memoranda setting it up. From the outside this makes the IRS look random and capricious in its application of tax law.


  2. Other than your post, is there a link out there for the public with the IRS announcement or from a secondary source, TNT or similar?

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Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.