IRS Changes FATCA Implementation Deadlines

Summary: The United States Internal Revenue Service recently issued Announcement 2012-42 (the Announcement), changing the deadlines for meeting due diligence and other requirements under the Foreign Account Tax Compliance Act (FATCA), provisions of which are contained in Sections 1471 through 1474 of the US Internal Revenue Code. The Announcement also clarifies the scope of so-called “grandfathered obligations,” which are exempt from at least certain FATCA requirements.