“The IRS announced its intention in Notice 2014-59 to amend temporary regulations it issued under the Foreign Account Tax Compliance Act (FATCA) on March 6, 2014, to modify the effective dates of (1) the standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee that is an entity under Regs. Sec. 1.1441-7(b); and (2) the rules under Regs. Sec. 1.6049-5(c) describing the circumstances under which a withholding agent or payer may rely on documentary evidence a payee provides instead of a withholding certificate to document the payee’s foreign status.”
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