12 July 2013, the Internal Revenue Service (IRS) and the Treasury
Department delayed certain provisions. While the announcement of a
further delay was met with relief, it has also sent mixed signals to the
financial services industry about how ready they should be with their
FATCA compliance program by July 2014.
On 22 October 2013, they released a notice giving Foreign Financial institutions (FFIs) further guidance to
implement their FATCA compliance program.
The notice highlights
details of the negotiated bilateral agreements, adds new rules and it
a draft agreement for institutions to sign if they want to avoid
penalties. While this notice serves as a next step in implementing a
FATCA compliance program, it is only relevant to those institutions
operating in model 2 Intergovernmental Agreements (IGA's) jurisdictions.
Institutions not operating in Model 1 or Model 2 jurisdictions will
need to comply with the final regulations released in January 2013.
Our white paper 'The delay to FATCA's roll out' is a global
examination of how the financial services industry is preparing for
FATCA compliance, how well they understand the FATCA legislation and the
impact it will have on the organization’s operations.
To download the paper: http://fatca.thomsonreuters.com/wp-content/uploads/2013/11/GRC00560_FATCA_wp_rollout_delay-FINAL.pdf