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On April 13, 2011, COT sent letters to James Fries, Director of the Financial Crimes Enforcement Network (FinCEN) at the United States Department of Treasury and Douglas Shulman, Commissioner of the Internal Revenue Service.
The letter to FinCEN proposed amending Final Rule 31 CFR Part 1010 so that officers and employees of U.S. publicly traded entities and their U.S. affiliates, with signature authority over an account included in a consolidated filing of the U.S. parent, are included in the exception for employees of publicly traded entities, regardless of which consolidated entity is the actual account holder. It also proposed this for employees of foreign affiliates of U.S. publicly traded entities, with signature authority over an account included in the consolidated filing of the U.S. parent, are similarly included in such exception. Moreover, it requested permitting taxpayers to rely on prior rules when responding to foreign financial account related questions on their timely filed 2010 individual income tax return.
The letter to Commissioner Shulman focused solely on permitting tax payers to rely on prior rules for their 2010 individual tax returns.
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