Treasury Department officials are preparing an arsenal of administrative weapons for Secretary Jacob Lew to use in the government's battle to prevent U.S. companies from reincorporating overseas in an effort to avoid paying federal taxes, otherwise known as tax inversion.
The U.S. Treasury has signed a number of intergovernmental agreements (IGAs) to combat offshore tax evasion and to comply with the Foreign Account Tax Compliance Act (FATCA). The U.S. has completed agreements with the Cayman Islands, Costa Rica, Denmark, France, Germany, Ireland, Japan, Mexico, Norway, Spain, Switzerland, and the United Kingdom.
The Foreign Account Tax Compliance Act (FATCA) compliance requirement for foreign banks dealing with the US has been delayed until July 1, 2014 so that these banks can continue to implement the changes and agreements necessary to avoid penalties. FATCA was enacted in 2010 to require that foreign banks report to the IRS information about American clients or otherwise face a 30% withholding penalty on all "dividends, interest or other payments they're slated to receive" from U.S. financial institutions.