FATCA Implementation: Take Two
May 12, 2011Miscellaneous
I've posted quite a bit about FATCA on this blog. Among these posts was a FATCA implementation report by Navigant prepared in the aftermath of Notice 2010-60 and sent to me by my colleague Rich Kando. This first report could be found here. Subsequent to the second round of guidance on FATCA, Notice 2011-34, Navigant, as many other service providers and advisors, prepared an updated implementation report. Just as with the first report, I think that Navigant has done a pretty good job of making sense out of these Notices, to the extent possible, and of creating some implementation flow-chart processes on which foreign financial institutions may rely now, in preparation of tackling FATCA. The report is attached below.