United States of America

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The US is among the Jurisdictions participating in the Convention On Mutual Administrative Assistance In Tax Matters. However, the US has not signed up to the amended Convention implementing the OECD’s Automatic Exchange of Information (AEoI). The AEoI consists of the Common Reporting Standard (CRS) and the Multilateral Competent Authority Agreement (MCAA).

Logo of the Federal Authorities of th Swiss Confederation

Swiss State Secretariat for International Financial Matters SIF comment (page 2):

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Model 1A IGAs are predicated on Reciprocal Reporting.

Hence, the US has FATCA Reporting obligations to the following Jurisdictions that have Model 1A IGAs:

Anguilla
Australia
Azerbaijan
Barbados
Belgium
Brazil
Canada
Cape Verde
China
Colombia
Costa Rica
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominica
Dominican Republic
Estonia
Finland
France
Germany
Gibraltar
Greece
Greenland
Guernsey
Guyana
Haiti
Honduras
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Jamaica
Jersey
Kazakhstan
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malaysia
Malta
Mauritius
Mexico
Montenegro
Netherlands
New Zealand
Norway
Panama
Peru
Poland
Portugal
Romania
Saint Lucia
Serbia
Seychelles
Slovakia
Slovenia
South Africa
Spain
Sweden
Thailand
Trinidad and Tobago
Tunisia
Turkey
Turkmenistan
United Kingdom

As of January 1, 2018 this list will include Switzerland. (Switzerland moves from a Model 2 to a Model 1 IGA from 1/1/2018.)

The following Model 2 IGAs refer directly to US Reciprocity on Reporting following reporting to the US:

Armenia
Austria
Bermuda
Chile
Iraq
Japan
Nicaragua
Paraguay
Taiwan

Whilst the counter-parties to the US often refer to these Agreements as “Treaties,” (and refer to the IGA as a Treaty in local law,) from a US point of view, the IGAs are not Treaties, they are merely Agreements.

US Treaties can found here:

https://www.senate.gov/legislative/treaties.htm

None of the IGAs above feature on the list of US Treaties.

The US Senate has not approved an income tax treaty or protocol since 2010.

The IGAs contain an explicit commitment from the US for full reciprocity. By way of example, here is an excerpt from the UK/US IGA:

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