Last week, the IRS issued Notice 2023-11 providing relief procedures for foreign financial institutions (“FFIs”) in countries with Model 1 intergovernmental agreements (“IGAs”) that have failed to provide U.S. taxpayer identification numbers (“TINs”) for certain preexisting accounts. Preexisting accounts are defined in Model 1 IGAs as a financial account maintained by a reporting financial institution as of June 30, 2014. Those FFIs in eligible Model 1 IGA jurisdictions that comply with the procedures described in the notice will avoid being identified by the U.S. Competent Authority as being in significant non-compliance with the IGA. (A list of U.S. IGAs, including Model 1 IGAs, along with other useful information regarding the status of all IGAs may be found at the Treasury’s FATCA page.)Continue Reading Treasury and IRS Extend Olive Branch to Reporting Model 1 FFIs and Model 1 IGA Jurisdictions Regarding U.S. TIN Reporting for Certain U.S. Accounts
IGA
Singapore Seeks Reciprocal IGA to replace Nonreciprocal IGA Currently In Effect
By S. Michael Chittenden on
Posted in FATCA, Tax Treaties
During a state visit by Singapore Prime Minister Lee Hsien Loong, Singapore and the United States announced they were negotiating a reciprocal Model 1 IGA. The countries had previously entered into a nonreciprocal Model 1 IGA in 2014 that went into effect on March 28, 2015. Unless Congress enacts legislation…
Continue Reading Singapore Seeks Reciprocal IGA to replace Nonreciprocal IGA Currently In Effect