On 2 April 2014, the US Internal Revenue Service
("IRS") released Announcement 2014-17, extending the
registration date for taxpayers, to be included on the initial IRS
list of compliant Foreign Financial Institutions
("FFIs").
The registration date was extended from 25 April to 5
May 2014.
Registration is important to avoid an automatic 30% US
withholding tax, which is being imposed on all US sourced income
after 30 June 2014.
In addition, IRS released an expanded list of countries under
the Intergovernmental Agreements ("IGA") process to
include Australia, which, as at 2 April 2014, had reached an in
substance agreement for an IGA with the IRS. This means that
Australian FFIs will report to the Australian Taxation Office
rather than the IRS and will reduce the level of compliance
required.