Today, in Notice 2015-66, Treasury and the IRS announced that they intend to amend the regulations under chapter 4 (sections 1471-1474) to extend the period of time that certain transitional rules will apply.  Under the amendments, gross proceeds withholding will apply only with respect to sales or other dispositions occurring after December 31, 2018.  The amendments will also extend the start date of withholding on foreign passthru payments to provide that a participating foreign financial institution (FFI) is not required to withhold tax on a foreign passthru payment made to a recalcitrant account holder or a nonparticipating FFI before the later of January 1, 2019, or the date of publication of final regulations defining the term foreign pass-through payment.  Treasury and the IRS also intend to extend until January 1, 2017, the availability of limited branch and limited FFI status and the deadline for a sponsoring entity to register its sponsored entities and redocument such entities with withholding agents.  In addition, in order to reduce compliance burdens on withholding agents that hold collateral as a secured party, the notice announces that Treasury and the IRS intend to modify the rules for grandfathered obligations with respect to collateral.