By Vanessa Tollis, Sara Verkest and Olivier Dauchez
On the afternoon of Friday May 2nd, 2014, the IRS unexpectedly announced that the years 2014 and 2015 will be a transition period for purposes of enforcement and administration of the Foreign Account Tax Compliance Act, or FATCA, but only for those financial institutions making a good faith effort to comply with the regime. In furtherance of this transition period, the IRS is extending certain transitional aspects of the due diligence requirements.
While this transition concept will be welcomed, it also adds some complexity to the already moving target of FATCA deadlines and procedures.