I. Introduction
On August 27, 2010, in Notice 2010-60 (the "Notice"), the Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued preliminary guidance pertaining to the new US withholding regime and information reporting requirements for certain accounts maintained by foreign institutions, commonly referred to as the Foreign Account Compliance Act provisions (the "FATCA provisions"), that were enacted as part of the Hiring Incentives to Restore Employment Act (the "HIRE Act") on March 18, 2010. The Notice constitutes preliminary guidance as to the positions that Treasury and the Service may take when future Treasury Regulations are issued. Treasury and the Service have requested comments on the issues addressed in the Notice and intend to issue regulations prior to December 31, 2012 (the effective date of the new rules discussed below).

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