In Notice 2014-33, issued on May 2, 2014, the IRS has offered some relief with regard to compliance with the
Foreign AccountTax Compliance Act (FATCA).  The IRS has stated that calendar years 2014 and 2015 will be
treated as transition years for IRS enforcement of due diligence, reporting, and withholding under FATCA and
that the agency will evaluate whether “good faith” efforts were made to comply with the requirements.  The
IRS has also announced that accounts opened after July 1, 2014, and before January 1, 2015, will be treated as
pre-existing accounts for FATCA purposes.