The US Department of the Treasury and the Internal Revenue Service released on February 20, 2014 two sets of final and temporary regulations. The first set contains changes to the provisions of Chapter 4 of the Internal Revenue Code commonly referred to as the Foreign Account Tax Compliance Act. The second set of regulations coordinate the documentation standards, reporting, and withholding rules relating to payments made to non-US and US persons (Chapters 3 and 61 and Section 3406 of the Code) with the FATCA regulations.
According to the Treasury press release, the new guidance represents the last substantial package of regulations necessary to implement FATCA. As such, the regulations contain numerous changes with the impact varying depending on the products or services and whether your activities are on shore or offshore. This insight looks at the more significant items contained in over 55o pages of regulations and the preambles which provide background on the amendments and regulations. Broadly speaking, the guidance provided is a compilation of many smaller changes and clarifications.