The Internal Revenue Service (IRS) and the US Department of the Treasury has revised the timelines for implementing reporting and withholding requirements under the Foreign Account Tax Compliance Act (FATCA).
These delays are very welcome to firms, particularly FFIs, still facing uncertain requirements and a short implementation timeframe.
Withholding on U.S. source income, such as interest and dividends, is delayed until July 1, 2014 while the registration portal to register as a PFFI or a deemed-compliant FFI is now expected to open on August 19.
Additionally, as part of the IRS notice, additional guidance has been provided on the treatment of financial institutions located in jurisdictions that have signed intergovernmental agreements for the implementation of FATCA (IGAs) but have not yet brought those IGAs into force.
These extensions will allow more time for foreign jurisdictions to enter into intergovernmental agreements (IGAs) with the US before FATCA comes into effect and will provide foreign financial institutions (FFIs) with more time to comply with the complex requirements of FATCA. However, it does not affect many of the longer term 2017, reporting and withholding deadlines.
RegRisk Legal Solutions Limited has taken all reasonable care and skill in the compilation of this guidance. However, it shall not be under any liability for loss or damage (including consequential loss) whatsoever or howsoever arising as a result of errors or omissions or the use of this publication by the users, whomever they may be. RegRisk Legal recognises that some of the terms appearing in this report are proprietary. All such trademarks are acknowledged and every effort has been made to indicate them by the normal UK publishing practice of capitalisation. The presence of a term in whatever form does not affect its legal status as a trademark.