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IRS and Treasury Department Propose Phase-In of FATCA Requirements  


Author:  Andrew P.  Solomon .; Judith R.  Fiorini.; Michael  Orchowski.


Source: Volume 29, Number 01, Fall 2011 , pp.37-46(10)




Journal of Taxation of Investments

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Abstract: 

In Notice 2011-53 the Treasury Department and the Internal Revenue Service have provided some timing relief to foreign financial institutions and foreign investment entities from the implementation of the FATCA-related provisions of the HIRE Act that require withholding by U.S. payors of certain payments to foreign financial institutions and certain foreign investment entities unless those institutions agree to comply with significant withholding, information reporting, and due diligence requirements. The notice outlines a phased implementation timeline that extends many FATCA-related deadlines beyond the January 1, 2013, effective date provided by the statute.

Keywords: Notice 2011-53; FATCA; foreign financial institutions; withholding; IRC Section 1471; IRC Section 1472

Affiliations:  1: Sullivan & Cromwell LLP.

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