Preface
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...
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