Tag Archives: Notice 2024-78

Part 4 – Notice 2023-11: Relief For Foreign Banks And The Hunt For Americans Abroad Extended For An Additional Three Years By Notice 2024-78

Prologue and introduction:

October 24, 2024 -Letter to Americans abroad from Kamala Harris

In a letter addressed to Americans abroad Vice President Harris said that she takes the concerns of US citizens overseas seriously, “whether it’s improving access to consular services, addressing the complex challenges you face with banking, taxation, and financial services, or ensuring equal treatment in immigration and citizenship processes.”

The full text of the letter may be found here.

https://www.democratsabroad.org/vp_harris_letter_to_americans_abroad

October 28, 2024 – Biden Treasury Letter To Americans Abroad – Notice 2024-78 – Either Comply With FATCA and U.S. Citizenship Taxation or Renounce U.S. Citizenship

As described in a short announcement from KPMG:

The IRS today released Notice 2024-78, extending the temporary relief provided in Notice 2023-11, subject to the procedures and requirements of Notice 2024-78, for certain foreign financial institutions required to report U.S. taxpayer identification numbers (U.S. TINs) for certain preexisting accounts as defined in an applicable Model 1 intergovernmental agreement (IGA).

If a foreign financial institution in an eligible Model 1 IGA jurisdiction complies with the procedures described in the notice, then the U.S. Competent Authority will not determine there is significant non-compliance with the reporting Model 1 FFI’s obligations under the IGA solely as a result of its failure to report U.S. TINs associated with its preexisting accounts for the 2025, 2026, and 2027 calendar years.

The text of Notice 2024-78 is here:

n-24-78

Notice 2024-78 is the first indication of how seriously (NOT) the Biden/Harris administration takes the concerns of Americans abroad. In brief, the message from the Biden Administration to (an update to Treasury Notice 2023-11) Americans abroad is:

Either comply with FATCA and U.S. citizenship taxation or renounce your U.S. citizenship!

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