Today, the IRS issued Notice 2010-60 related to the March 18, 2010 Hiring Incentives to Restore Employment (“HIRE”) Act of 2010. The HIRE Act imposed substantial reporting and withholding obligations on non-US financial institutions and certain other non-US entities in an effort to locate US account holders who are evading their US tax obligations.

The new Notice is intended to clarify a number of issues that have arisen in relation to reporting and withholding requirements for non-US financial institutions and other non-US entities. Highlights of the Notice are as follows...