2013

• FFIs may begin to apply to enter into FFI agreements

• To qualify for PFFI status by the time FATCA withholding first becomes effective on January 1, 2014, an FFI will be required to execute an FFI agreement with the IRS by June 30, 2013

2014

• ATCA withholding begins on withholdable payments that are US-source FDAP

• PFFIs must begin reporting limited information relating to US investors and non-US non-FFI investors for the prior year (name, address, taxpayer identification number, account number (if any), investment balance)...