Westpac Hit Renews Bank Tax Worries; Is IRS's APA Program A Solution?


It isn't the first or only foreign bank to feel the sting of the U.S. Internal Revenue Service, but news that Westpac took a one-time charge of $76 million for the year ended September 30, 1992, for its inter-branch currency swap and forward transactions has shaken the market. The incident has renewed concerns among foreign banks about U.S. tax laws covering cross-border trading.

Those jitters are well justified, tax experts surveyed say. In fact, says John Clark, senior vice president and

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