U.S.A.: IRS publishes guidance to jurisdictions with an Intergovernmental Agreement not yet in force
On 4 August 2016, the Internal Revenue Service (IRS) published an announcement (2016-27) providing guidance to jurisdictions that are treated as if they have an Intergovernmental Agreement (IGA) in effect and FFIs located in those jurisdictions. Each jurisdiction that is treated as if it has an IGA in effect and that wishes to continue to be treated as if it has an IGA in effect must provide the Treasury Department, by 31 December 2016, with a detailed explanation of why the jurisdiction has not yet brought the IGA into force. The jurisdiction must also provide a step-by-step plan that they intend to follow in order to sign the IGA (if it has not been signed) and bring the IGA into force.
The list of jurisdictions treated as if they have an IGA in effect (the “IGA List”) may be found on the Treasury Department website. As of the date of publication of this Taxflash, the United States has signed IGAs with 83 jurisdictions; of those IGAs, 61 are in force. The United States has also reached agreements in substance with 30 jurisdictions.
We are currently reviewing the Notice and will share with our customers any further relevant information as it becomes available.
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