Trade Associations Request Additional Extension of FATCA Phased Timeline (with Lofchie Music Selection)

SIFMA, the American Bankers Association ("ABA"), The Clearing House Association L.L.C. ("The Clearing House") and the Institute of International Bankers ("IIB") submitted the comment letter linked below to the U.S. Department of the Treasury and the Internal Revenue Service ("IRS") requesting an additional extension of the Foreign Account Tax Compliance Act ("FATCA") phased timeline.

The letter states that, without the Final Guidance, firms cannot do the following:

  • complete their implementation plans,
  • finalize budgets,
  • prepare needed written procedures,
  • hire and train internal personnel,
  • educate clients and
  • develop and test the systems changes required for compliance with FATCA's requirements.

The letter also asserts that significant gaps in guidance remain, as well as numerous unanswered implementation questions that must be addressed by the IRS.

The Associations asked that the start of FATCA withholding be postponed until January 1, 2015 and reporting under FATCA for 2014 and 2015 be postponed until March 31, 2016 in order to ensure a smooth transition to the FATCA regime and minimize the prospects of over-withholding, as well as the potential for significant disruptions to financial markets. The Associations stressed that its requested extended deadlines assume that all "Final Guidance" by Treasury and the IRS under FATCA be issued by December 31, 2013.

Lofchie Music Selection: "Give Me Just a Little More Time".

See: SIFMA Comment Letter.

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