Intergovernmental Agreements

News & Analysis as of

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

IRS Extends FATCA Registration Deadline to May 5, 2014

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

BVI Financial Institutions now able to register with the IRS for a GINN

In a welcome announcement made on 2 April 2014, the US Internal Revenue Service (IRS) made provision for Financial Institutions in jurisdictions that have already reached an "agreement in substance" on the terms of a Model 1...more

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

CRS Report To Congress On Internet Governance

On November 13, 2013, the Congressional Research Service ("CRS") issued a report to Congress entitled "Internet Governance and the Domain Name System: Issues for Congress." The focus of the report is the United States'...more

Capital Thinking: Tax and Retirement

Tax Legislative Activity - Senate Finance Chairman Announces Drafts to be in Legislative Langauge - Senate Finance Committee Chairman Max Baucus (D-MT) announced last week that tax reform discussion drafts to be...more

"G20 Leaders Endorse Greater International Tax Transparency"

At last month’s summit in St. Petersburg, Russia, G20 leaders backed two ambitious proposals issued by the Organization for Economic Co-operation and Development (OECD), including the establishment of a global model for the...more

Denis Kleinfeld: FATCA – Predictions of Implementation Failure Proving True

Denis Kleinfeld, Of Counsel to Fuerst Ittleman David & Joseph, is one of the nation”s most prolific writers in the field of International Tax Planning, and in recent years has focused his attention on the Foreign Account Tax...more

Cayman Islands Government Announces FATCA Intergovernmental Agreement

The Cayman Islands government announced on August 13, 2013 that it has concluded negotiations with the US government on a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act...more

The New World Wide Web: FATCA Inspires a Global Effort to Fight Tax Evasion

The rapid evolution of the Foreign Account Tax Compliance Act (“FATCA”) from a U.S. driven effort to crack down on U.S. offshore tax evaders into an information reporting mechanism being considered for adoption throughout the...more

CIS Legal Update - May 2013: Russia and the United Arab Emirates Take Measures to Encourage and Improve Investment Security

Russia ratified an intergovernmental Agreement with the United Arab Emirates (hereinafter - UAE) on the Encouragement and Mutual Security of Investments (executed on June, 28, 2010) along with the accompanying Protocol...more

Cayman Islands commended by the OECD in latest peer review report

The Organisation for Economic Co-operation and Development (“OECD”) recently published a report in which the Cayman Islands was commended for the “streamlined, efficient and responsive procedures it has is in place to...more

A nuisance called FATCA – Does the UK/US IGA make it bearable?

The introduction by the US of the Foreign Account Tax Compliance Act 2010 (FATCA) set the proverbial cat amongst the pigeons in the international loan financing markets by requiring foreign and domestic borrowers, lenders and...more

BVI and Cayman to enter into FATCA Model 1 agreements with United States

Both jurisdictions also pledge to sign up to “UK FATCA” - The US Foreign Account Tax Compliance Act, commonly referred to as FATCA, became effective earlier this year, and foreign financial institutions (“FFIs”) in...more

Final Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more

Cayman Islands to Enter into a Model 1 IGA

The Cayman Islands announced on March 15 that it intends to enter into a Model 1 Intergovernmental Agreement (IGA) with the Internal Revenue Service for Foreign Account Tax Compliance Act (FATCA) compliance purposes...more

Corporate and Financial Weekly Digest - March 22, 2013

In this issue: - NASDAQ Proposes Internal Audit Function Requirement for Listed Issuers - FINRA’s Frequently Asked Questions on Electronic Blue Sheet Submissions Updated Regarding Order Execution Time -...more

Son of FATCA – Swiss/U.K. Agree on Information Exchange

In what is clearly the first of many to come intergovernmental agreements similar to the Foreign Account Tax Compliance Acct (FATCA) adopted by the U.S. in 2010, the governments of Switzerland and the United Kingdom entered...more

What You Need to Know About FATCA’s Impact on Non-U.S. Retirement Plans

The Internal Revenue Service recently published final regulations under the Foreign Account Tax Compliance Act (FATCA), which are effective immediately. FATCA imposes significant reporting obligations on both non-U.S....more

Member States Sign Agreement to Establish Unified Patent Court

On Tuesday, the Council of the European Union announced that twenty-four member states had signed the international agreement that would establish a Unified Patent Court (UPC), a specialized court having exclusive...more

The Treasury Department and IRS Release Final FATCA Regulations

On January 17, 2013, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released long-awaited final regulations on the set of statutory rules commonly referred to as FATCA. As more fully described in...more

Highlights of Recently Released FATCA Regulations

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

Significant Changes Made in Final FATCA Regulations

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

FATCA: Final Regulations Raise Questions for Trust Practitioners

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

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