Round 3 of FATCA guidance: IRS Notice 2011-53 provides transitional rules for Foreign Financial Institutions

On July 14, 2011, the Internal Revenue Service (IRS) issued Notice 2011-53 (the Notice), which provides a timeline for Foreign Financial Institutions (FFIs) and U.S. withholding agents to implement the various provisions under the Foreign Account Tax Compliance Act (FATCA) of 2009, which was enacted in the Hiring Incentives to Restore Employment Act of 2010. Notice 2011-53 supplements and modifies the guidance provided in Notice 2010-60 and Notice 2011-34.