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This article reaches readers shortly after the US Treasury and the IRS department issued Notice 2011-53, dated July 14 2011, providing a workable timeline for FFIs and U.S. withholding agents to implement the various requirements of FATCA.
Specifically, the notice phases in the implementation of FATCA in the following manner:
- An FFI must enter an agreement with the IRS by June 30, 2013, to ensure that it will be identified as a participating FFI in sufficient time to allow withholding agents to refrain from withholding beginning on January 1, 2014.
- Withholding on U.S. source dividends and Interest paid to non-participating FFIs will begin on Jan. 1, 2014, and withholding on all withholdable payments (including on gross proceeds)...
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