U.S.A.: Revised Intergovernmental Agreement Models
The U.S. Treasury has posted revised templates of Intergovernmental Agreement Models I and II and related Annexes.
There are now five versions submitted for consideration according to whether the potential partner country has a Tax Information Exchange Agreement (TIEA) or Double Taxation Treaty (DTT) with the U.S.A., as follows:
- A reciprocal version of Model I for jurisdictions that have signed a DTT or TIEA with the U.S.A.;
- A non-reciprocal version of Model I for jurisdictions that have signed a DTT or TIEA with the U.S.A.;
- A non-reciprocal version of Model I for jurisdictions that have not (yet) signed a DTT or TIEA with the U.S.A.;
- A version of Model II for jurisdictions that have signed a DTT or TIEA with the U.S.A.;
- A version of Model II for jurisdictions that have not (yet) signed a DTT or TIEA with the U.S.A.
These Models and the related revised Annexes can be found on the U.S. Treasury website.
The above information is not intended to be exhaustive. We will continue to monitor the U.S. Internal Revenue Service and commentator publications and will provide further relevant information in due course.
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