U.K.'s "Son of FATCA"

The United Kingdom has announced that it has reached agreement for a FATCA type reciprocal tax sharing agreement between the Isle of Man and the U.K. Under the new agreement, which will be modeled after the recently signed U.S.-U.K. FATCA Intergovernmental Agreement, the two countries will automatically exchange tax information with respect to their residents on an annual basis. The U.K. also announced that it was seeking to enter into similar agreements with two other Crown Dependencies, Jersey and Guernsey. In a Joint Statement issued on December 7th, the Chief Ministers of Jersey and Guernsey acknowledged that the U.K. was seeking to "promote more widely as a new international standard the principles of the U.S. Foreign Account Tax Compliance Act . . ." and indicated that Jersey and Guernsey would be pressing the U.K. to make clear U.K. efforts to promote the adoption of automatic exchange of information worldwide would "ensure a level playing field for all finance centres competing in the global market." In that regard there are indications that the U.K. may also seek to enter into such agreements with its overseas territories.

See: UK Treasury press release andJoint Statement from Jersey and Guernsey Ministers.Questions regarding this item may be directed to Dan Mulcahy.