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US unveils FATCA Model 2 agreement

21 November 2012

Ralph Cunningham - ITR


The US has published the final template for inter-governmental agreements (IGA) with foreign jurisdictions to implement the Foreign Account Tax Compliance Act (FATCA).

The template, known as Model 2, requires the partner country to “direct and enable” its financial institutions to register with the Internal Revenue Service (IRS) by January 1 2014 and abide by the provisions of the FFI [foreign financial institution] Agreement, which outlines that the FFI is compliant with FATCA, the law that  requires FFIs to disclose certain information about their US accountholders or pay a withholding tax of 30%.  

The US authorities had previously published the Model 1 IGA, which applies to jurisdictions where local laws prohibit FFIs from reporting directly to...



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