Bermuda Agrees to FATCA Model 2 IGA

Bermuda's Minister of Finance, Bob Richards, has announced that Bermuda and the U.S. Treasury Department have concluded negotiations on a FATCA Intergovernmental Agreement ("IGA") and have initialed the IGA. As previously announced, the IGA is a Model 2 type agreement requiring Bermuda financial institutions to report information with respect to financial accounts held directly or indirectly by U.S. persons to the U.S. IRS. The IGA must be approved by the UK pursuant to a July 15, 2010 Letter of Entrustment with respect to tax information exchanges. The text of the IGA will not be released until it is approved by the UK and signed by representatives of both Bermuda and the United States.

See: Bermuda to Sign Model 2 FATCA IGA with U.S. (May 1, 2013). See also: Treasury Department Releases Model 2 FATCA IGA (November 15, 2012); Treasury Revises Model IGAs under FATCA (July 15, 2013). For a full discussion of FATCA, see Lofchie'sGuide to Hedge Fund Regulation - FATCA Chapter.