Alert! IRS Proposed Remittance Rule: No Exemption Like Regulation E

Even institutions that process only a limited number of remittance transfers could find themselves subject to new tax collection and reporting obligations under the IRS Remittance Transfer Tax, which is a 1% federal tax on certain outbound international money transfers initiated after December 31, 2025. Importantly, financial institutions cannot rely on the traditional Regulation E remittance transfer annual exemption to avoid compliance responsibilities for covered transfers.

The IRS has issued proposed regulations implementing the new excise tax on certain remittance transfers under Section 4475 of the Internal Revenue Code, enacted through the One, Big, Beautiful Bill Act (OBBBA). While the tax is imposed on the sender, the remittance transfer provider becomes liable for the tax if it is not properly collected at the time of the transfer. As a result, even institutions with relatively low remittance transfer volumes may need to establish new operational processes, tax collection procedures, recordkeeping practices, and reporting controls.

Join us for a timely webinar designed to break down the proposed IRS rule and provide practical guidance on what your institution should be doing now to prepare. We will discuss key compliance requirements, implementation challenges, operational considerations, and upcoming deadlines including the expiration of penalty relief for remittance transfer providers that fail to deposit the correct amount of remittance transfer tax after September 30, 2026.