This notice also announces certain intended amendments to the regulations under sections 1441, 1442, 1471, and 1472, including amendments providing that a withholding agent or FFI may treat an obligation (which includes an account) held by an entity that is opened, executed, or issued on or after July 1, 2014, and before January 1, 2015, as a preexisting obligation for purposes of sections 1471 and 1472, subject to certain modifications set out in the notice.
Taxpayers may rely on Notice 2014-33 regarding these proposed amendments to the regulations prior to their issuance.
Notice 2014-33 will be published in Internal Revenue Bulletin 2014-21 on May 19, 2014.
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