The Inland Revenue Service (IRS) have indicated that certain FATCA implementation timelines are to be postponed by six months. As a result, the timelines for undertaking due diligence for US withholding agents, Foreign Financial Institutions (FFIs) in countries with an Intergovernmental Agreement (IGA) and FFIs in countries without an IGA are to be aligned thereby reducing significantly the administrative burden. Moreover, the Irish tax authorities (Revenue) have indicated that discussions are still on schedule for Ireland to sign up to an IGA by year end. The final form IGA should closely follow the UK IGA, published on 12 September, with some differences in Annex II in terms of the list of exempt financial institutions, etc. Legislation will need to be enacted in order to enforce the provisions of Ireland's IGA, once agreed. The Finance Bill 2013 should address this although it is understood that the detail will be left to subsequent Regulations.