The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information reporting requirements for foreign financial institutions and non-financial foreign entities and the related withholding regime under FATCA. The proposed regulations effectively delay reporting and withholding in large part by providing for expanded categories of “grandfathered obligations.” The proposed regulations also delay compliance procedures for foreign passthru payments until 2017 at the earliest and request comments on a number of items.

On February 8, 2012, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations to implement certain provisions of Internal Revenue Code (IRC) Sections 1471-1474 (enacted as part of the Hiring Incentives to Restore Employment Act of 2010, or the HIRE Act). Sections 1471-1474 are commonly referred to as “FATCA” (as a holdover from the earlier Foreign Account Tax Compliance Act pursuant to which the provisions were originally proposed).