Every foreign entity must take steps
immediately to determine whether FATCA will apply
to it and, if so, whether FATCA registration will be required by
April 25, 2014.
FATCAi will go into effect on July 1, 2014. Foreign
entities that must be FATCA-compliant by July 1, 2014 must register
with the IRS by April 25, 2014. Beginning on July 1, 2014,
non-compliant foreign entities that receive payments or allocations
of certain U.S.-source income generally will be subject to a new 30
percent U.S. withholding tax on such income.
Many types of foreign entities (i) are subject to deferred
registration deadlines, (ii) are not subject to registration
requirements, but have other compliance obligations under FATCA, or
(iii) are exempt from FATCA altogether. At a minimum,
every foreign entity should undertake a
self-analysis now to determine (1) its FATCA
classification, (2) whether it must register with the IRS and (3)
if required, whether registration must be completed by
