Key takeaways 

• Yesterday the IRS issued limited relief regarding the implementation of the so-called “FATCA” (Foreign Account Tax Compliance Act) withholding and information reporting rules. 
• The relief delays until June 30, 2013 the date for “foreign financial institutions” (“FFIs”) to enter into withholding agreements with the IRS, and delays the start date for withholding tax under the FATCA rules until January 1, 2014, and for certain categories of payments until January 1, 2015. 
• The relief also clarifies that the grandfather rule applicable to fixed-term obligations (not including equity) outstanding on March 18, 2012 includes certain obligations issued by FFIs.