Client Alert

| July 26, 2011

IRS Issues Revised Phased-in Timeline for FATCA Implementation

As previously reported, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2011-53 on July 14, 2011 (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).

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. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383