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

Blank Rome LLP

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.

First, the IRS released the first public list of Foreign Financial Institutions (FFIs) who have registered on the IRS FATCA website to become compliant and participating FFIs. According to the IRS, approximately 77,000 financial institutions have registered since the registration portal opened on January 1. The published registration list will be updated monthly going forward. In a statement, Deputy Assistant Secretary for International Tax Affairs Robert Stack said that the high level of registrations so far showed “strong international support” for FATCA. The registration list even includes several hundred Russian banks, which registered directly with the IRS after the U.S. broke off negotiations with Russia over the conflict in the Ukraine.

Simultaneously, the IRS announced the release of its “FATCA List Search and Download Tool,” which is accessible here.  The list contains all of the FFIs registered, accepted, and assigned a Global Intermediary Identification Number (GIIN) in accordance with FATCA regulations to date.  Users can use the Search and Download Tool to find out if FFIs have registered with FATCA.  Users are able to download the entire list of registered FFIs or search for a specific one.  The IRS has also published a User Guide to the FFI List Search and Download Tool, which is available here.

Second, the Treasury Department announced that Barbados and the United Arab Emirates have reached Model 1 intergovernmental agreements (IGAs) in substance under FATCA. Treasury maintains a list of all IGAs that have been reached to date on its website (accessible here), which currently totals 68. Here is a list of all countries which have signed IGAs to date, and the applicable dates of the agreements:

Model 1 IGAs

Australia (4-28-2014)

Belgium (4-23-2014)

Canada (2-5-2014)

Cayman Islands (11-29-2013)

Costa Rica (11-26-2013)

Denmark (11-19-2012)

Estonia (4-11-2014)

Finland (3-5-2014)

France (11-14-2013)

Germany (5-31-2013)

Gibraltar (5-8-2014)

Guernsey (12-13-2013)

Hungary (2-4-2014)

Honduras (3-31-2014)

Ireland (1-23-2013)

Isle of Man (12-13-2013)

Italy (1-10-2014)

Jamaica (5-1-2014)

Jersey (12-13-2013)

Liechtenstein (5-19-2014)

Luxembourg (3-28-2014)

Malta (12-16-2013)

Mauritius (12-27-2013)

Mexico (4-9-2014)

Netherlands (12-18-2013)

Norway (4-15-2013)

Spain (5-14-2013)

United Kingdom (9-12-2012)

Model 2 IGAs

Austria (4-29-2014)

Bermuda (12-19-2013)

Chile (3-5-2014)

Japan (6-11-2013)

Switzerland (2-14-2013)

Here is a list of all countries which have reached IGAs in substance:

Model 1 IGAs

Azerbaijan (5-16-2014)

Bahamas (4-17-2014)

Barbados (5-27-2014)

Brazil (4-2-2014)

British Virgin Islands (4-2-2014)

Bulgaria (4-23-2014)

Colombia (4-23-2014)

Croatia (4-2-2014)

Curaçao (4-30-2014)

Czech Republic (4-2-2014)

Cyprus (4-22-2014)

India (4-11-2014)

Indonesia (5-4-2014)

Israel (4-28-2014)

Kosovo (4-2-2014)

Kuwait (5-1-2014)

Latvia (4-2-2014)

Lithuania (4-2-2014)

New Zealand (4-2-2014)

Panama (5-1-2014)

Peru (5-1-2014)

Poland (4-2-2014)

Portugal (4-2-2014)

Qatar (4-2-2014)

Romania (4-2-2014)

Singapore (5-5-2014)

Slovak Republic (4-11-2014)

Slovenia (4-2-2014)

South Africa (4-2-2014)

South Korea (4-2-2014)

Sweden (4-24-2014)

Turks and Caicos Islands (5-12-2014)

United Arab Emirates (5-23-2014)

Model 2 IGAs

Armenia (5-8-2014)

Hong Kong (5-9-2014)

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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