Nearly 100 Countries Agree to FATCA IGAs by June 30 Deadline

Nearly 100 countries signed FATCA Intergovernmental Agreements ("IGAs") or agreed in substance to the terms of such an agreement prior to the July 1, 2014 implementation date of FATCA.

The IRS announced that any country that agreed in substance to the terms of an IGA on or before June 30, 2014 would be treated as having an IGA in effect at least through December 31, 2014. The vast majority of jurisdictions elected to enter into a Model 1 type IGA under which financial institutions in such jurisdictions will provide information on direct or indirect U.S. account holders directly to their local taxing authorities, which will transmit such information to the U.S. IRS. Thirteen countries to date have elected to adopt a Model 2 form of IGA under which their financial institutions will report account information directly to the U.S. IRS.

Countries that agreed in substance to IGAs over the last couple of days are as follows: Algeria, Bahrain, Cabo Verde, the Dominican Republic, Greenland, Haiti, Malaysia, Montenegro and Serbia (all Model 1). Moldova, Nicaragua and San Marino have agreed in substance to the terms of a Model 2 IGA. Additionally, Russia (which, due to issues with Ukraine, has been unable to enter into an IGA with the United States) adopted legislation, which President Putin signed on June 30, that permits Russian banks to register under FATCA with the IRS and provide account information to the IRS directly.

See: Cabinet Compilation of FATCA Agreements and Statements, Organized by Country; Cabinet FATCA Materials (both resources are available to Cabinet subscribers only).For more information, please contact Daniel Mulcahy and Mark Howe.