New IRS Notice Extends Timelines and Provides Additional Guidance Regarding FATCA
By KRISTEN CHANG WINCKLER, DAVID MAKSO & GRACE MINJEONG SUR
This alert outlines the key aspects of IRS Notice 2013-43 which postponed the initial withholding under the Foreign Account Tax Compliance Act (FATCA) for six months. This Notice also extended certain other timelines including the timeline for implementing new account opening procedures and due diligence on preexisting obligations. In addition, this Notice notes that any jurisdiction that has signed but has not yet brought into force an intergovernmental agreement (IGA) will be treated as having an IGA in effect. As of this date, IGAs have been entered into with Denmark, Germany, Ireland, Japan, Mexico, Norway, Spain, Switzerland, and the United Kingdom.