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ARTICLE · 30 SEPTEMBER 2015

US FATCA – Extended Transitional Rules And Model 1 IGA Reporting Deadlines

Harneys
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Many partner jurisdictions that have signed IGAs or reached an agreement in substance on the text of an IGA continue to work through their internal procedures to bring the IGA into force.

United StatesCorporate/Commercial Law
Kate Taft
Kate Taft
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Notice 2015-66 was issued on 18 September 2015 announcing that the US Treasury Department and IRS intend to amend section 1471-1474 of the regulations.

Transitional Rules

The transitional rules provided in Notice 2015-66 are intended to allow for and facilitate an orderly transition for withholding agents and FFIs regarding FATCA compliance and are in response to growing concerns on how the phase-out of transitional rules may affect information reporting and withholding systems.

Specifically, Sections 1471-1474 will extend:

  1. The date when withholding on gross proceeds and foreign passthru payments will begin.
  2. Transitional rules to the application of FFI status for limited branches" and "limited foreign financial institutions" that are members of expanded affiliated groups.

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