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FATCA is a dauntingly complex body of law. Although the Code provisions span fewer than 10 pages, the Treasury regulations (final, temporary, and proposed) and their preambles recently surpassed the 700-page mark, not to mention the five model IGAs and their annexes, numerous IRS guidance materials, 43 signed IGAs with various jurisdictions (as of October 1, 2014), and 58 IGAs in substance that are treated as in effect (as of October 1, 2014). Although originally scheduled to take effect after 2013, FATCA withholding has been delayed and now applies to withholdable payments” made starting July 1, 2014. In Notice 2013-43, the IRS agreed that certain jurisdictions will be treated as having an IGA in effect even though the particular jurisdiction has signed an IGA but has not yet brought it into force. Notice 2014-33 announced that 2014 and 2015 will be transition periods for IRS enforcement and administration of FATCA’s reporting, withholding, and due diligence requirements, including a good-faith efforts standard under the Treasury regulations.