Wormwood to Screwtape: Just ignore the 544 pages of IRS tax regulations recently issued. Surely there can't be an accounting for what you didn't know?

My Dear Uncle Screwtape,

I am delighted to inform you of my successful efforts to have the IRS issue 544 pages of federal income tax regulations interpreting the Foreign Account Tax Compliance Act of 2009 (FATCA). Very keen on my part to suggest that there should be withholding of tax on certain payments to foreign financial institutions (FFIs) that do not agree to report foreign account information about US owners. Surely no one will possibly understand. My Taxpayers will further feel justified in claiming ignorance and then wham - I catch them in the net that they have been lulled into. How trusting these Taxpayers are in the notion that ignorance is bliss.

Some of that schooling has finally paid off, Uncle Screwtape.

And I believe it brilliant of me to weave purported tax simplification, through model intergovernmental agreements, into part of that 544 pages of income tax regulations. 544 pages of regulations on withholding? Wow. Mis-truth has always been one of our strongest tools. You have always told me to suggest that they need more regulations Uncle. My finest hour will be that I suggested the IRS to replace 389 pages of proposed tax regulations on this subject with 544 pages of final tax regulations. Dazzling!

Uncle, the IRS will ease the rules into effect over a phase in period with timelines for withholding, due diligence, and reporting requirements that are the dream of all attorneys - tax complexity at its best, Uncle. Years and years to implement and comprehend.

I hope this continued good work, Uncle, will allow you to overlook my massive slip-up in allowing my Taxpayers around the Fiscal Cliff - they should have all perished over that cliff Uncle. I still have heartburn over the lowering of the capital gains rates, indexing of alternative minimum tax, and revived depreciation deductions and credits.

In hopes that you are temporarily pacified, Uncle Screwtape, your adoring nephew,

Wormwood 

With attribution and appreciation to C. S. Lewis from his book The Screwtape Letters.

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