FATCA: Revised Deadlines: IRS and Treasury Department Issue Notice Postponing Certain FATCA Deadlines and Expanding Scope of FATCA “Grandfather” Rules

Yesterday, the IRS and Treasury Department issued Announcement 2012-42 (the “Announcement”), which delays certain FATCA compliance deadlines and identifies three new classes of “grandfathered obligations.” Key changes noted in the Announcement include the following:

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