On Friday, May 2, 2014, the .  IRS Notice 2014-33 announces that during this transition period, the IRS will take into account the extent of good faith efforts to comply with the requirements of the chapter 4 regulations and the temporary coordination regulations by Foreign Financial Institution (FFI) and withholding agents. The IRS will take into account whether a withholding agent has made reasonable efforts during the transition period to modify its account opening practices and procedures to document the chapter 4 status of payees, apply the standards of knowledge provided in chapter 4, and, in the absence of reliable documentation, apply the presumption rules of §1.1471-3(f).  Additionally, for example, the IRS will consider the good faith efforts of a participating FFI, registered deemed-compliant FFI, or limited FFI to identify and facilitate the registration of each other member of its expanded affiliated group as required for purposes of satisfying the expanded affiliated group requirement under §1.1471-4(e)(1).

FATCA, which was approved approved in 2010, will require foreign banks and other financial institutions to hand over information to the Internal Revenue Service about Americans’ accounts worth more than $50,000.