The IRS notice further eases, but does not delay, FATCA
implementation.
On May 2, the Internal Revenue Service (IRS) published Notice
2014-33 (the Notice),1 which announced that calendar
years 2014 and 2015 will be regarded as a "transition
period" for purposes of IRS enforcement and administration of
the due diligence, reporting, and withholding provisions under the
Foreign Account Tax Compliance Act (FATCA).2 The Notice
also announced extended deadlines for implementing certain
onboarding and due diligence procedures as well as certain relief
relating to "limited foreign financial institutions" and
"limited branches." Finally, the Notice also announced
minor amendments to the Treasury regulations relating to certain
due diligence standards and procedures to be applied by withholding
agents.3
