Key takeaways 

• The IRS has issued proposed regulations on FATCA, providing guidance on a wide range of issues under FATCA's withholding and reporting regime.
• The FATCA grandfather date is extended from March 18, 2012 to January 1, 2013.
• The proposed regulations reserve on when payments by foreign financial institutions will be treated as "passthru payments" and defer the start date for withholding on foreign "passthru payments" until January 1, 2017.
• The proposed regulations expand the category of "deemed compliant" foreign financial institutions.
• Substantial changes were made to reduce the diligence procedures for accounts.