On 12 July, just one working day before the secure portal to be used by FFIs to register their status was due to go live, the US Internal Revenue Service ("IRS") issued Notice 2013-43 ("the Notice") announcing the delay to the implementation of FATCA. Whilst many FFIs will welcome the extra time to prepare for FATCA compliance, others will be reassessing their plans as projects are geared to move into the delivery phase. There are practical steps that FFIs can take to allow them to maintain the momentum of their projects and to reassess next steps.
The impact of the US regulations will now start to bite, from 1 July 2014 six months later than originally planned. In addition, the IRS has also announced that FFIs will not be required to report on accounts for the year ended 31 December 2013.
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