IRS Announces Extended FATCA Deadlines

On October 24, 2012, the U.S. Internal Revenue Service (IRS) issued Announcement 2012-42: Timelines for Due Diligence and Other Requirements Under FATCA (Announcement). The Announcement provides that final regulations (Final Regulations) issued under the tax provisions commonly referred to as the Foreign Account Tax Compliance Act (FATCA) ¹, when issued, will extend certain deadlines for compliance with FATCA and also clarify the scope of "grandfathered obligations" under FATCA. This client alert summarizes key aspects of the Announcement. ²

Background

On February 8, 2012, the U.S. Treasury Department (Treasury) and the IRS released substantial proposed regulations (Proposed Regulations) implementing FATCA. Additionally, on September 12, 2012, the United States and the United Kingdom entered into an agreement intended to facilitate implementation of FATCA based on domestic reporting and to improve reciprocal information sharing between the two countries, based on