This month, the main focus overseas is on the US, where the Treasury Department has released two versions of the Model Intergovernmental Agreement as an alternative approach to implementing the information reporting and withholding tax provisions of FATCA, and on the CJEU where there has been a recent AG opinion that challenges the conclusions of the court in the Marks & Spencer case. There have also been some consultations issued in the international tax area and draft regulations have been published in relation to the excluded countries exemption within the new CFC regime.
