No need for treaty or TIEA to become a FATCA Partner Country

Michael Danilack, deputy commissioner (international) in the IRS Large Business and International Division, said June 19 that neither a tax treaty nor a tax information exchange agreement need be in place for a country to participate in the Intergovernmental Approach to FATCA. His statement was made at a seminar in the U.S. This is consistent with information regarding certain tax haven jurisdictions having already approached the U.S. Treasury about entering into agreements.

Denise Hintzke of Deloitte was able to ask whether financial institutions in a FATCA Partner country could opt-out of the agreement. This might avoid having to develop multiple approaches to FATCA compliance – one or many for FATCA Partner countries and others. However, he could not respond because the agreements have not yet been finalized.