Following Announcement 2012-42 ( the US Internal Revenue Service (IRS) has delayed the timelines for withholding agents and foreign financial institutions (FFI’s) to complete the due-diligence requirements as detailed in FATCA (Foreign Account Tax Compliance Act).

Primary causes for the delay are discussions about and objections from FFI’s, individuals with dual citizenship and expats. The IRS has opted to delay the Fatca start date to January 2014, while FFI’s will now have until January 2017 to begin withholding US-derived tax from client returns.

The following table summarizes the dates by which withholding agents and FFI’s must fully implement new account opening procedures to identify account holders and the dates by which withholding agents and financial institutions must complete the review and documentation of all preexisting accounts for purposes of applying the relevant Treasury regulations.

We will continue to monitor FATCA developments for you and report relevant developments on VBK Blog and through VBK social media. If you have any specific questions or comments, please contact your account manager(s). If you are not a VBK client please use our e-mail address to contact us.