Fatca FFI draft agreement finally released


The US Treasury has released proposed guidance for foreign financial institutions (FFIs) entering into agreements directly with the US Internal Revenue Service (IRS) under the Foreign Account Tax Compliance Act (Fatca).

The long-awaited draft FFI agreement includes proposed guidance not only for FFIs reporting directly to the IRS, but also those reporting via the so-called model 2 intergovernmental agreement (IGA).

The model 2 IGA sees FFIs reporting directly to the IRS when they are either

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