IRS extends deadlines for FATCA
Revised timeline but much to do
Published November 2012
On October 24, 2012 the IRS released Announcement 2012-42 which extends the deadlines for certain FATCA requirements. The agreements that Foreign Financial Institutions (FFIs) must enter into with the IRS to ensure FATCA compliance will now become effective on January 1, 2014 (changed from July 1, 2013).
The Announcement also provides new timelines for due diligence, withholding and reporting requirements that are in line with those included in the Model Intergovernmental Agreement published in July 2012.
We believe that these extensions are not a reason to slow down preparations for FATCA. Companies that relax their sense of urgency around implementing compliance programs may quickly find themselves facing the new deadlines, and quite possibly some implementation challenges that have yet to be discovered.
To discuss your FATCA compliance programme, please contact a member of our FATCA team.