Earlier this month the Revenue Commissioners circulated draft guidance notes on the implementation of FATCA in Ireland and draft financial accounts reporting regulations. These draft publications follow on from the FATCA enabling legislation contained in the Finance Act 2013. The Revenue Commissioners indicated that they would be accepting observations and comments on the draft guidance and regulations up to the end of May. It is understood that a number of trade associations including the IFIA are considering whether to make a submission. In the context of funds the guidance considers among other matters (i) when a fund is exempt from FATCA reporting requirements under Annex II of the Ireland-US Intergovernmental Agreement or separately under the US Treasury Regulations, (ii) which 'investment entity' may have reporting obligations where a fund does not fall within the category of a non-reporting Irish Financial Institution and (iii) the documenting of new accounts on a merger of two funds.