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Memorandum: Notice 2013-43 - Revised Timeline and Other Guidance Regarding the Implementation of the Foreign Account Tax Compliance Act

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To:      Clients & Friends
From:      Armin Gray
Re:      Notice 2013-43 – Revised Timeline and Other Guidance Regarding the Implementation of The Foreign Account Tax Compliance Act (“F.A.T.C.A.”)
Date:      July 18, 2013

On July 12, 2013, the Internal Revenue Service (“I.R.S.”) released Notice 2013-43 (the “Notice”), which revises the timelines included in the final F.A.T.C.A. regulations for withholding agents and foreign financial institutions (“F.F.I.'s”) to begin their due diligence, withholding, and information reporting requirements. Specifically, the Notice provides for the following:

  • A six-month extension for when withholding will begin (i.e., payments after June 30, 2014).
  • A six-month extension for grandfathered obligations.
  • A six-month extension for implementing new account opening procedures and certain due diligence obligations.
  • A six-month extension for expiring withholding certificates. Thus, withholding certificates and documentary evidence that would otherwise expire on December 31, 2013, will expire instead on June 30, 2014.
  • A six-month extension for qualified intermediaries (“Q.I.'s”), withholding foreign partnerships (“W.P.'s”), or withholding foreign trusts (“W.T.'s”) agreements that would otherwise expire on December 31, 2013.