IRS extends FATCA Compliance Date for one year to September 30, 2016

Well, it’s been quite a week. At approximately 4:45 p.m. today the IRS issued a notice confirming that the FATCA implementation date will be extended to September 30, 2016. As you know Canada has a Model 1 IGA. Assuming the correctness of the post in the above tweet:

Model 1 IGA Jurisdictions for Which the Obligation to Exchange Is In Effect

For those Model 1 IGA jurisdictions where the obligation to exchange is in effect now, Notice 2015-66 provides that FFIs in that country will be treated as FATCA compliant, and not subject to withholding, so long as the partner jurisdiction notifies the U.S. before September 30 that it requires more time, and “provides assurance that the jurisdiction is making good faith efforts to exchange the information as soon as possible.” Notice 2015-66 does not, however, change the deadline for FFIs to report information to their local tax authority, which remains governed by law of that country.

We have instructed our legal counsel to notify the Government of Canada (and they have) of this development and request that the Government of Canada NOT disclose your banking information to the IRS.

It’s been quite a week. We will keep you posted.


John Richardson



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2 comments on “IRS extends FATCA Compliance Date for one year to September 30, 2016
  1. David says:

    What about those of us suffering under the yoke in Australia?


  2. […] transfer your FATCA data to the IRS by the September 30, 2015 deadline. In addition (as you know) our lawyers have notified the Government lawyers that, we know, that the are not required to abide by the September 30 […]


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