The Internal Revenue Service and the US Department of Treasury have issued “Announcement 2012-42: Timelines for Due Diligence and Other Requirements under FATCA” (the Announcement). The Announcement provides new timelines for withholding agents and foreign financial institutions (FFIs) to complete due diligence and other requirements. Additionally, it provides guidance regarding whether certain instruments meet the definition of a “grandfathered obligation” and extends the timeline regarding the imposition of withholding tax on certain gross proceeds. 

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