SECTION 2. IN GENERAL

Treasury and the IRS have received comments regarding issues arising from the repeal of section 163(f)(2)(B), including comments requesting guidance regarding when obligations will be considered to be in registered form and requesting clarification with respect to certain collateral consequences of the repeal of section

163(f)(2)(B). In addition, Treasury and the IRS are aware that the implementation of section 501 of the HIRE Act, which added new sections 1471 to 1474 (commonly known as FATCA) to the Code, may require changes to the documentation collected by foreign financial institutions (including qualified intermediaries) and withholding agents with respect to payees and account holders.

Section 3 of this notice provides guidance addressing when obligations will be considered to be in registered form. Section 4 of this notice provides interim guidance with respect to the application of the portfolio interest exception to certain obligations in registered form issued after March 18, 2012, and before January 1, 2014. Section 5 of this notice addresses the continued availability of the existing exception from reporting of interest or original issue discount under section 6049 for certain foreign-targeted short-term obligations. Finally, section 6 of this notice provides guidance with respect to procedures required to comply with the foreign-targeting rules of section 4701(b) as amended by section 502 of the HIRE Act.