Going global? Be aware of the many changes taking place in the international tax area. After successfully obtaining names of US account holders from UBS in Switzerland, IRS is gearing up for enforcing further compliance in this area. There may be new tax traps for the unwary after the enactment of FATCA in the Hire Act of last March. Controlled foreign corporations are likely to meet the definition of the newly defined “Non Financial Foreign Entities” which can have stringent reporting requirements and increased penalties for non compliance.