Separately, the IRS is operating a voluntary disclosure initiative, which encourages taxpayers with undeclared accounts and income to come forward, pay penalties and likely avoid prosecution. The deadline for entering that program is Aug. 31.
About 15,000 taxpayers came forward during a similar program in 2009, and the IRS has been using the information it gleaned during that process to pursue others, Shulman said April 6. Yesterday, the agency asked a court for a summons that would require HSBC Holdings Plc to disclose information about its U.S. clients with accounts in India.
The information released today deals largely with foreign financial institutions and doesn't address other questions attorneys have about how the new law will work, said Charles Kolstad, an attorney at Venable LLP in Los Angeles who represents the owners and beneficiaries of trusts.
The law, he said, imposes new reporting requirements on beneficiaries of foreign trusts, even in cases where the beneficiaries may not know trust details. That's an area where the IRS will need to release future guidance.
"This really doesn't answer most of the questions that people have," Kolstad said.