IRS Will Extend Some FATCA Transition Rules

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In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules:

(1) the date for when withholding on gross proceeds and foreign passthrough payments will begin;

(2) the use of limited branches and limited foreign financial institutions (limited FFIs); and

(3) the deadline for a sponsoring entity to register its sponsored entities and redocument such entities with withholding agents.

According to the IRS, the Notice provides additional time for withholding agents and FFIs to address the phase-out of the transitional rules.   The Notice also provides information on the exchange of information by Model 1 IGA jurisdictions with respect to 2014.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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