Business Services Industry
Sec. 1441 voluntary compliance program.
Tax Adviser, The, March, 2005 by Kantor, Adam; Sylvia, Sharlene M.
The IRS has launched a voluntary compliance program (VCP) under Sec. 1441 for withholding agents (such as financial institutions) that make payments of U.S.-source dividends, interest, rents, royalties and other fixed or determinable, annual or periodical (FDAP) income to foreign persons; see Rev. Proc. 2004-59.
The VCP responds to comments from financial institutions that wanted to disclose and resolve compliance issues associated with implementing final regulations under Secs. 1441-1464 and 6041-6050S. When these financial institutions started to implement the final regulations, they began identifying tax deficiencies and failures in their systems. These entities told the IRS that complying with the final regulations required ongoing documentation of account...
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