IRS Extends FATCA Implementation Deadlines (For The Last Time?)

In response to continuing concerns raised by foreign financial institutions, the IRS has issued new guidance further delaying a number of the FATCA implementation deadlines in the form of Announcement 2012-42 (the "Announcement"), offering FFIs much needed additional time to prepare.

The Announcement extends a number of important due-diligence, withholding, and reporting deadlines originally laid out in the Proposed Regulations, and these extended deadlines are expected to be incorporated in the final regulations when issued.

Extended Deadlines under the IGAs

The previously announced Model Intergovernmental Agreements ("IGAs") broadly mirrored the deadlines contained in the Proposed Regulations, but relaxed certain requirements. For example, under these models, FFIs covered by an IGA would not be required to report information regarding accounts maintained in the 2013 calendar year until September 30, 2015. In addition, procedures to collect certain information