On 20 February 2014, the US Department of Treasury and the Internal Revenue Service released temporary regulations that revise and clarify the final FATCA regulations (Temporary Regulations) as well as temporary regulations coordinating the final regulations under Chapters 3 and 61 of the IRS code with the final FATCA regulations (Coordination Regulations).

Deloitte has produced an initial analysis of some of the most significant updates made to the final FATCA regulations and also some of the noteworthy coordinating changes to Chapters 3 and 61, and other related provisions.

The new rules do not provide any further extensions to the effective date of FATCA, or to the required timeframes in which a Foreign Financial Institution (FFI) that has entered into an FFI Agreement must comply with the due diligence, withholding or reporting obligations under that agreement.

The Temporary Regulations can be accessed here and the Coordination Regulations can be accessed here.

Download our initial analysis.

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