MODEL AGREEMENT AS FATCA ALTERNATIVE

DEAR BUBBAS AND BUBBETTES,

Here is another interesting update on the nasty hegemonic FATCA fiasco.  Enjoy.

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UNITED STATES – ANALYSIS OF MODEL AGREEMENT AS FATCA ALTERNATIVE

KPMG LLP,  July 30, 2012.

The U.S. Treasury Department on July 26, 2012, released two versions of the Model I Intergovernmental Agreement (Model IGA) to implement the information reporting and withholding tax provisions of the Foreign Account Tax Compliance Act (FATCA), together with a joint message with France, Germany, Italy, Spain, and the United Kingdom endorsing the agreement.

KPMG’s analysis of the distinctions between the Model IGAs and the requirements under the proposed regulations examines the following areas:

• Modification of definition of financial institution
• Significant reliance on self-certifications
• Modification to account identification timeline
• Elimination of certain reporting requirements
• Elimination of withholding requirement for gross proceeds
• Modification to the limited foreign financial institution (FFI) rule
• Additional carve outs for retirement plans
• Reciprocity—potential for future requirements for U.S. withholding agents

KPMG LLP: Model I Intergovernmental Agreement released as alternative to FATCA regime (See attached).

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