On July 12, 2013, the US Treasury Department issued Notice 2013-43 which extended the implementation deadline of most FATCA rules for an additional six months.  This has moved the general implementation deadline for FATCA from January 1, 2014 to July 1, 2014.

Still, US persons holding foreign accounts will be impacted by FATCA sooner rather than later. Many foreign financial institutions are planning or have begun closing accounts held by US persons and other institutions have begun efforts to determine whether individuals are US persons based on the location of their birth or other information on file. While the delayed announced in Notice 2013-43 is good news for the financial institutions that must implement systems to identify US persons, the delay is unlikely to provide much relief to US taxpayers holding these accounts because foreign financial institutions are already moving to identify them in anticipation of complying with FATCA.