The IRS recently issued Announcement 2016-27, which provides guidance
on which jurisdictions are treated as if they have an
intergovernmental agreement (IGA) in effect, but have not yet
brought their IGA into force. In 2012, the U.S. government released
Model 1 and Model 2 IGAs to facilitate implementation of the
Foreign Account Tax Compliance Act (FATCA). As of the date of
Announcement 2016-27, the United States had signed IGAs with 83
jurisdictions, 61 of which are in force. The United States has also
reached agreements in substance with 30 jurisdictions.
This announcement provides that, on Jan. 1, 2017, Treasury will
begin updating the IGA list to provide that certain jurisdictions
that have not brought their IGAs into force will no longer be
treated as if they have an IGA in effect. Each jurisdiction with an
IGA that is not yet in force and that wishes to continue to be
treated as having an IGA in effect must comply with prescribed
requirements by Dec. 31, 2016.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.