- That a withholding agent or FFI may treat an obligation (including an account) held by an entity that is opened, executed, or issued on or after July 1, 2014, and before Jan. 1, 2015, as a preexisting obligation for purposes of Secs. 1471 and 1472, subject to certain modifications described in the notice;
- Additional guidance under Sec. 1471 concerning the requirements for an FFI (or a branch of an FFI, including a disregarded entity owned by an FFI) that is a member of an expanded affiliated group of FFIs to be treated as a limited FFI or limited branch, including the requirement for a limited FFI to register on the FATCA registration website;
- A modification to the standards of knowledge for withholding agents under Regs. Sec. 1.1441-7(b) for accounts documented before July 1, 2014; and
- A revision to the definition of a reasonable explanation of foreign status in Regs. Sec. 1.1471-3(e)(4)(viii).
Tuesday, May 6, 2014
IRS announces two-year FATCA enforcement transition period
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