IRS Delays Effective Dates For Implementation of FATCA

The IRS has agreed to delay by six months the implementation of the key provisions of the Foreign Account Compliance Act ("FATCA"). Notice 2013-43, which announced the delay, also includes relief for foreign financial institutions ("FFIs") located in countries that have entered into Model 1 type intergovernmental agreements ("IGAs") with the IRS¹. Treasury has concluded such IGAs with a number of countries, but the IGAs have not yet come into force due to hold ups in the Senate Foreign Relations Committee. Under the Notice, any FFI that is located in a country that is listed by the IRS as having signed an IGA will be permitted to register and obtain a global intermediary identification number ("GIIN") as a registered deemed compliant FFI even if the IGA is not yet in force. As a reminder, Canada and the United States announced last November that they are in discussions to enter into an IGA by the end of this year, but that has not yet occurred. The Notice also makes