The Countdown Begins as the IRS prepares to Release the First List of Approved Foreign Financial Institutions in Compliance with FATCA

The IRS recently issued Announcement 2014-17, providing an update on jurisdictions treated as having intergovernmental agreements (IGAs) with the United States in order to implement the Foreign Account Tax Compliance Act (FATCA). As of the date of the announcement, the United States had signed IGAs with 26 jurisdictions and was close to obtaining agreements with many others.

The announcement recognizes the practical concerns expressed by Foreign Financial Institutions (FFIs) who have reached "agreements in substance" on the terms of an IGA and attempts to provide clarity to these FFIs. While the text of an IGA will not be published by the IRS until the IGA is actually signed, the IRS will nonetheless provide a list of IGAs where there is an agreement in substance and specify whether the relevant IGA is a Model 1 or a Model 2.

The announcement also allows FFIs 10 additional days to register in preparation for FATCA, and to still ensure that the FFIs' Global Intermediary Identification Number (GIIN) will appear on the first public list of approved FFIs.

The announcement can be found at this link: Announcement 2014-17

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