On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence requirements under Internal Revenue Code sections 1471-1474, commonly referred to as the Foreign Account Tax Compliance Act (FATCA). Treasury and the IRS intend to amend the regulations under sections 1471-1474 to implement the extensions. According to the Treasury Press Release, the extensions should allow more time for foreign jurisdictions to enter into intergovernmental agreements (IGAs) with the United States before FATCA comes into effect and should provide foreign financial institutions (FFIs) with more time to comply with the complex requirements of FATCA. Prior to the issuance of the amended regulations, taxpayers may rely on Notice 2013-43.
The Notice additionally provides that:
- The 6-month extension does not affect the existing 2017 effective date for withholding on gross proceeds, foreign pass-thru payments, and payments of U.S. source FDAP income with respect to offshore obligations by persons not acting in an intermediary capacity.
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