It’s Just a Phase: The “Phased Implementation” of FATCA Under Notice 2011-53

It’s Just a Phase: The “Phased Implementation” of FATCA Under Notice 2011-53

On July 14, 2011, Treasury and the Internal Revenue Service (IRS) released Notice 2011-53 (the Notice), which provides transition rules for implementation of the Foreign Account Tax Compliance Act (FATCA). Although the statutory effective date of the FATCA provisions is January 1, 2013, the...

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