Initial Analysis on Updated FATCA and Coordination Regulations
Foreign Account Tax Compliance Act (FATCA)
On Thursday, February 20, 2014, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released temporary regulations that revise and clarify the final FATCA regulations (“Temporary Regulations”). The government also released temporary regulations coordinating the final regulations under Chapters 3 and 61 of the Internal Revenue Code (“Code”) with the final FATCA (Chapter 4) regulations (“Coordination Regulations”). The new rules do not provide any further extensions to the effective date of FATCA or to the required timeframes in which an FFI that has entered into an FFI Agreement (a “participating FFI” or “PFFI”) must comply with the due diligence, withholding or reporting obligations under the that agreement.
In this initial analysis, we highlight some of the most significant updates made to the final FATCA regulations and also some of the noteworthy coordinating changes to Chapters 3 and 61 and other related provisions.
- Modifications to definitions affecting classification of entities
- Expanded affiliated group also redefined
- Other definitional and interpretive changes
- Due Diligence
- FFI Agreement
- Coordination Regulations
- Future Guidance
Details to bulleted highlights are included in downloadable Deloitte’s initial analysis along with copies of the Treasury Department and IRS release of updates to final FATCA Regulations and Coordination Regulations. For more information please contact a Deloitte FATCA Leader or click here.
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