Treasury update on FATCA intergovernmental agreements, negotiations  

November 8: The Treasury Department today announced that the United States is engaged with more than 50 countries and jurisdictions with respect to the Foreign Account Tax Compliance Act (FATCA).

Earlier this year, Treasury published a model intergovernmental agreement for implementing FATCA and announced the development of a second model agreement. These models serve as the basis for concluding bilateral agreements with interested jurisdictions.


The Treasury Department and the IRS will finalize the regulations implementing FATCA “in the near term” according to today’s release.

Existing intergovernmental agreements

Today’s Treasury release notes that the United States has already concluded a bilateral agreement with the United Kingdom, and is in the process of finalizing an intergovernmental agreements with:


  • France
  • Germany
  • Italy
  • Spain
  • Japan
  • Switzerland
  • Canada
  • Denmark
  • Finland
  • Guernsey
  • Ireland
  • Isle of Man
  • Jersey
  • Mexico
  • The Netherlands
  • Norway

Ongoing negotiations

Treasury reports that the United States is actively engaged in a dialogue towards concluding an intergovernmental agreement with:


  • Argentina
  • Australia
  • Belgium
  • The Cayman Islands
  • Cyprus
  • Estonia
  • Hungary
  • Israel
  • Korea
  • Liechtenstein
  • Malaysia
  • Malta
  • New Zealand
  • Slovak Republic
  • Singapore
  • Sweden

Today’s Treasury release states that it is expected that negotiations with several of these jurisdictions by will be concluded by year-end.

Future agreement being explored

The jurisdictions with which Treasury is working to explore options for intergovernmental engagement include:


  • Bermuda
  • Brazil
  • British Virgin Islands
  • Chile
  • Czech Republic
  • Gibraltar
  • India
  • Lebanon
  • Luxembourg
  • Romania
  • Russia
  • Seychelles
  • Sint Maarten
  • Slovenia
  • South Africa

The Treasury Department release states that the United States will continue its outreach to interested jurisdictions that wish to consider an intergovernmental approach to implementing FATCA, including participation in a meeting hosted by the Qatar Central Bank in early December to provide information about FATCA and the intergovernmental agreements to invited senior government officials and financial institutions in the Gulf Cooperation Council.




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©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

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