Client Alert
| July 20, 2011
IRS Issues Phased-in Timeline for FATCA Implementation
On July 14, 2011, the Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued Notice 2011-53 (the "Notice") which provides transitional relief and describes the timeline for the implementation of the Foreign Account Tax Compliance ("FATCA") provisions that were enacted in March 2010 as part of the Hiring Incentives to Restore Employment Act of 2010 (the HIRE ACT). While the FATCA provisions were originally set to be effective on January 1, 2013, after receiving comments from affected parties Treasury and the IRS recognized the timing challenges related to the development of compliance, reporting and withholding systems necessary to comply with these provisions. As a result, the Notice provides for a phased implementation of the various FATCA provisions.
This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
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