The IRS recently issued Announcement 2016-27, which provides guidance on which jurisdictions are treated as if they have an intergovernmental agreement (IGA) in effect, but have not yet brought their IGA into force. In 2012, the U.S. government released Model 1 and Model 2 IGAs to facilitate implementation of the Foreign Account Tax Compliance Act (FATCA). As of the date of Announcement 2016-27, the United States had signed IGAs with 83 jurisdictions, 61 of which are in force. The United States has also reached agreements in substance with 30 jurisdictions.  

This announcement provides that, on Jan. 1, 2017, Treasury will begin updating the IGA list to provide that certain jurisdictions that have not brought their IGAs into force will no longer be treated as if they have an IGA in effect. Each jurisdiction with an IGA that is not yet in force and that wishes to continue to be treated as having an IGA in effect must comply with prescribed requirements by Dec. 31, 2016.

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