Effective Date for FATCA Implementation Delayed by Six Months

The U.S. Internal Revenue Service (“IRS”) has issued a Notice which postpones by six months, from 1 January, 2014 to 1 July, 2014, the effective date for certain requirements under the Foreign Account Tax Compliance Act (“FATCA”).

Among other things, foreign financial institutions (“FFIs”) will not be required to register with the IRS or, where applicable, enter into an FFI agreement with the IRS until June 30, 2014. The IRS will publish the first list of global intermediary identification numbers (“GIINs”) by June 2, 2014, with monthly updates to follow. In order for an FFI to be on the first published list of GIINs, it now will need to register by April 25, 2014.

A copy of the full text of the Notice can be found here.

http://www.irs.gov/pub/irs-drop/n-13-43.pdf

We will be issuing a full legal update on the implications of FATCA for Cayman Islands financial institutions once the terms of the Cayman Islands Government’s Model 1 Intergovernmental Agreement (“IGA”) have been finalized.

If you have any questions regarding the matters covered in the Alert above, please contact the Attorney below or your usual Loeb Smith & Brady contact:

Daniel Loeb
+44 207 183 7966
daniel.loeb@loebsmith.com