SECTION 1. PURPOSE

This notice provides interim rules under sections 932(c) and 7654(e) concerning the statute of limitations on assessment of the U.S. income tax liability (if any) of a U.S. citizen or resident alien who takes the position that he or she is a bona fide resident of the U.S. Virgin Islands and the U.S. filing obligations of such an individual. This notice also announces that the Treasury Department and Internal Revenue Service (IRS) intend to issue regulations under sections 932(c) and 7654(e). Finally, this notice announces that the Treasury Department and the IRS are studying the feasibility of an automatic exchange of information program with the U.S. Virgin Islands Bureau of Internal Revenue concerning income tax information of individual taxpayers. Such a program for the timely exchange of equivalent data in a form compatible with IRS systems may eliminate the reporting requirements set forth in the interim rules. Until the regulations are issued, taxpayers may rely on this notice.