Treasury Considering Limited Relief for ‘In Substance’ FATCA IGAs #GATCA

The U.S. Treasury Department might provide limited relief to jurisdictions that reached agreements in substance with the United States under the Foreign Account Tax Compliance Act but don’t sign the agreements by the December 31 deadline, according to Steven Musher, IRS associate chief counsel (international).

In Announcement 2014-17, 2014-18 IRB 1001, released April 2, Treasury said it would treat jurisdictions with which it has reached an agreement in substance on the terms of a Model 1 or Model 2 IGA as having an IGA in effect until December 31, 2014, the date by which the IGA must be signed for that status to continue without interruption. To be eligible for that treatment, jurisdictions had to reach an agreement in substance by June 30.

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