FATCA - Revised timelines for compliance by U.S. withholding agents, foreign financial institutions 

July 24: Charts (prepared by KPMG LLP and provided below) summarize the revised timelines for FATCA compliance by U.S. withholding agents and participating foreign financial institutions, and reflect changes announced by the IRS in Notice 2013-43.


The IRS on July 12 released Notice 2013-43 [PDF 51 KB], revising the timelines under the FATCA final regulations for U.S. withholding agents and participating foreign financial institutions to begin their due diligence, withholding, and reporting requirements pursuant to sections 1471-1474.

Notice 2013-43 provides a six-month extension for when withholding will begin (i.e., payments after June 30, 2014) and for implementing new account-opening procedures, as well as related requirements to comply with FATCA.

The timeline for foreign financial institutions to register (among other things) as participating foreign financial institutions (PFFI) was also extended, with the registration portal expected to open on August 19, 2013.

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