Key takeaways 

• The IRS has issued final regulations under FATCA providing guidance on a wide range of issues. 
• FATCA withholding will not apply to payments under obligations that are outstanding on January 1, 2014, or to any proceeds from the disposition of such obligations. This represents a one-year extension from prior guidance. 
• Although the final regulations continue to reserve on the definition of “foreign passthru payments,” obligations that give rise to foreign passthru payments are grandfathered if such obligations are outstanding on or prior to six months after final regulations addressing these payments are adopted. 
• A manager of investment funds is permitted to act as a “sponsoring entity” that registers the managed funds under FATCA and performs the applicable due diligence, withholding and reporting obligations on behalf of the funds.