U.S. Initials FATCA IGAs with Spain and Switzerland

The Spanish Ministry of Finance has announced that Spain and the United States have initialed an Intergovernmental Agreement ("IGA") under FATCA based on the reciprocal Model I government-to-government form. A copy of the IGA has not yet been released. The Swiss State Secretariat for International Affairs has announced that Switzerland and the United States had initialed an IGA based on the Model II Form IGA. Under Model II, foreign financial institutions report account information directly to the U.S. IRS at the direction of the foreign government, supplemented by requests from the U.S. to the foreign government for information with respect to recalcitrant account holders (generally those who refuse to consent to their information being reported to the U.S.) that are reported to the IRS by the financial institutions on a group basis. The text of the Swiss IGA will be released after it is formally signed. A copy of the Swiss Government's press release is attached here.