Limited FATCA transition period announced; Earlier this month the IRS issued Notice 2014-33 announcing that the calendar years 2014 and 2015 would be regarded as a transitional period for IRS enforcement and administration of FATCA. During that period the IRS will take into account the extent to which good faith efforts have been made to comply with FATCA obligations. It also provides that a withholding agent of a foreign financial institution can treat an account held by an entity that is opened, executed or issued on or after 1 July 2014 and before 1 January 2015 as a pre-existing account for FATCA purposes.