IGAs

News & Analysis as of

United States and Brazil Sign FATCA Intergovernmental Agreement

The United States and Brazil have signed a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”). The Brazilian IGA is intended to simplify FATCA information...more

U.S. Tax Developments Affecting Financial Institutions and Products

Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more

The Steady March Toward FATCA Implementation: 77,000 Financial Institutions Registered and Nearly 70 IGAs Reached

On June 2, 2014, the U.S. Treasury and the Internal Revenue Service announced further developments as the July 1 implementation date of the Foreign Account Tax Compliance Act (FATCA) quickly approaches....more

FATCA and the Cyprus – US Connection

THE US DEPARTMENT OF TREASURY HAS ANNOUNCED that Cyprus and the US have reached agreement in substance as regards the Inter-Governmental Agreement for FATCA and Cyprus has consented to being included ...more

Israel Inks Model 1 FATCA IGA

Bloomberg BNA is reporting that Israel has signed a FATCA IGA. The agreement is a Model 1 agreement, meaning that Israeli financial institutions will will report information about U.S. customers’ accounts to the Israeli tax...more

Tax Talk -- Volume 7, No. 1 -- April 2014

In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more

"Treasury and IRS Release FATCA Regulations"

New Regulations Address Some Concerns and Coordinate FATCA Rules with Other Reporting and Withholding Rules - On February 20, 2014, the Department of the Treasury and the IRS issued a comprehensive set of final and...more

BVI concludes negotiations with US on FATCA

The British Virgin Islands Government has today announced the conclusion of negotiations with the United States on a Model 1 Intergovernmental Agreement (IGA) under the US Foreign Account Tax Compliance Act (FATCA)....more

Canada And U.S. Finally Reach Agreement On FATCA

The long awaited Foreign Account Tax Compliance Act United States – Canada Intergovernmental Agreement (IGA) was released on February 5, 2014, and as anticipated will expand the sharing of information between the two...more

U.S. Signs Four More FATCA IGA’s

On February 5, 2014, the Treasury Department announced that it had recently concluded FATCA IGA’s with Canada, Hungary, Italy, and Mauritius. All four agreements were reciprocal Model 1 agreements. In other words, FFI’s in...more

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

U.S. Signs FATCA IGA with Italy

Tax Analysts’ Tax Notes Today reports that on January 10, 2014, the U.S. signed a FATCA IGA with Italy, which became the 13th country to sign such a deal with the U.S. ...more

Tax Law Blog: The Impact of FATCA

The U.S. government loses an estimated $150 billion in revenue each year from offshore tax shelters. The Foreign Account Tax Compliance Act (FATCA), which became law in March 2010, is designed to prevent tax evasion by U.S....more

U.S. Signs Agreements with Cayman Islands and Costa Rica to Implement FATCA

On November 29, the United States signed intergovernmental agreements with the Cayman Islands and Costa Rica to implement the Foreign Account Tax Compliance Act (FATCA). ...more

United States Signs FATCA Intergovernmental Agreement With the Cayman Islands

The US Department of the Treasury recently announced that the United States has signed a “Model 1” intergovernmental agreement (an “IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”) with the Cayman...more

U.S. Signs FATCA IGA With France

Bloomberg BNA reports that the Treasury Department announced on November 14, 2013, that the U.S. and France have signed a Model 1 FATCA IGA. In other words, the IGA will require banks in France to report tax information about...more

IRS releases long-awaited draft FFI Agreement and previews updates to FATCA regulations

The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA). ...more

U.K.-Cayman IGA Signed

The United Kingdom (U.K.) has published an agreed intergovernmental agreement (IGA) with the Cayman Islands. The IGA was signed on 5th November and is intended to improve international tax compliance by providing for domestic...more

FATCA Compliance Guidance Issued for Foreign Financial Institutions

The IRS has issued Notice 2013-69, which provides guidance to foreign financial institutions (FFIs) entering into a FATCA compliance agreement with IRS. The 50-page Notice also provides guidance to FFIs and their...more

FBAR Non-filers Beware of Global Information Exchange Agreements

At the most recent meeting of the Finance Ministers and Central Bank Governors on July 19 & 20, 2013 they said “We are committed to automatic exchange of information as the new, global standard and we fully support the OECD...more

IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting

On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43, which extended the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on...more

Treasury Delays FATCA Deadlines by Six Months

On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more

FATCA Alert: US announces six month postponement to the implementation dates for FATCA - the impact on UK FIs

On 12 July, just one working day before the secure portal to be used by FFIs to register their status was due to go live, the US Internal Revenue Service ("IRS") issued Notice 2013-43 ("the Notice") announcing the delay to...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43, released on July 12, 2013, announces the Internal Revenue Service’s (the IRS) and the Department of the Treasury’s intent to amend final Treasury regulations implementing the U.S. Foreign Account Tax...more

Tax Talk -- Volume 6, No. 2 -- July 2013

In This Issue: IRS Leaves Potential REIT Conversions Hanging; IRS Proposes to Relax Wash Sale Rules for Floating NAV Money Market Fund Share Redemptions; IRS Confirms Mexican Land Trust Is Not Trust Under U.S. Tax Law;...more

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