Important FATCA Developments Concerning Registration and IGAs

April 4, 2014

Two notable FATCA developments have just occurred.

  • The IRS has extended the key date for FATCA registration from April 25, 2014 to May 5, 2014. This means that FFIs now have ten additional days to register to be assured that their names appear on the first IRS FFI List published June 2, 2014. In addition, FFIs that register by June 3, 2014 will be assured that their names appear on the second IRS FFI List published July 1, 2014. FFIs should finalize FATCA registration by May 5, 2014 to avoid any potential erroneous 30% withholding by prime brokers and other withholding agents on July 1, 2014, the date when FATCA withholding commences.
  • The British Virgin Islands and several other countries have been added to Treasury’s list of jurisdictions that are treated as having an intergovernmental agreement (an “IGA”) in effect.

For the list of new jurisdictions that are treated as having an IGA in effect, see:

For the official IRS announcement concerning the postponement of the registration deadline, see:

Our prior memorandum discussing FATCA registration and other issues can be accessed here:

For background information on FATCA, see our prior memoranda:

Our webinar regarding FATCA can be accessed here:

We will continue to keep you updated on any developments regarding FATCA. If you have any questions regarding the registration process or the general application of FATCA to your organization, please contact: Jon Brose (212-574-1615,, Jim Cofer (212-574-1688,, Ron Cima (212-574-1471,, or Dan Murphy (212-574-1210,