IRS, Treasury Intend to Extend the Time Certain FATCA Transitional Rules Apply

1.  IRS, Treasury Intend to Extend the Time Certain FATCA Transitional Rules Apply


Notice 2015-66 announces that the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) intend to amend regulations under sections 1471-1474 to extend the time that certain FATCA transitional rules will apply.  Specifically, the amendments will extend:

(1) the date for when withholding on gross proceeds and foreign passthru 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.

In addition, in order to reduce compliance burdens on withholding agents that hold collateral as a secured party, the notice announces that Treasury and the IRS intend to amend the regulations under chapter 4 to modify the rules for grandfathered obligations in relation to collateral.

Finally, the notice provides information on the exchange of information by Model 1 IGA jurisdictions with respect to 2014.

 

More information can be found here.