FFIs, grandfathered obligation On October 24, 2012, the Internal Revenue Service (IRS) and the US Department of Treasury (Treasury) issued "Announcement 2012-42: Timelines for Due Diligence and Other Requirements under FATCA" (the Announcement).
On July 14, 2011, the Internal Revenue Service (IRS) announced rules in Notice 2011-53 (the Notice) that modify FATCA’s January 1, 2013 statutory effective date, as a result of the comments submitted to the IRS and Treasury Department (Treasury) relating to the practical challenges of implementing FATCA by the statutory effective date.
On January 7, 2011, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations that would impose information collection and reporting requirements on US financial institutions with respect to bank deposit interest paid to non-US persons (the "2011 proposed regulations").
On December 9, 2009, as part of a package to extend certain expiring tax provisions, the US House of Representatives passed HR 4213 (the House Bill), a bill containing several of the international tax proposals first introduced in the Foreign Account Tax Compliance Act of 2009 (FATCA).
A United States person with a financial interest in, or signature authority over, “foreign financial accounts,” may be required to file a “Report of Foreign Bank and Financial Accounts” (Form TD F 90-22.1, or “FBAR”).
Several US Internal Revenue Service (IRS) officials have recently indicated that TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) (FBAR) should be filed by United States persons that own interests in certain non-US investment vehicles, such as hedge funds.