Client Alert
On May 2, 2014, the IRS released Notice 2014-33, offering transitional relief for the enforcement and administration of FATCA. The Notice also redefines “preexisting obligation” to include obligations that are issued on or after July 2, 2014, and before January 1, 2015.
The Treasury intends to amend the final FATCA regulations to adopt the rules summarized below. However, in the meantime, taxpayers may rely on the instructions in the Notice.
