The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information reporting requirements for foreign financial institutions and non-financial foreign entities and the related withholding regime under FATCA. The proposed regulations effectively delay reporting and withholding in large part by providing for expanded categories of “grandfathered obligations.” The proposed regulations also delay compliance procedures for foreign passthrough payments until 2017 at the earliest and request comments on a number of items.
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