|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).|
Model 1A IGAs are predicated on Reciprocal Reporting.
Hence, the US has FATCA Reporting obligations to the following Jurisdictions that have Model 1A IGAs:
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:
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:
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: