Three approaches to FATCA compliance

There are three approaches to FATCA compliance being developed:

1. The Intergovernmental Approach outlined in the Joint Statement released with the proposed regulations;
2. Direct reporting to the IRS facilitated by an intergovernmental agreement;
3. Direct reporting to the IRS as prescribed in the proposed regulations.

Many countries have questioned the commitment which would be required to support the Intergovernmental Approach. A facilitated direct reporting approach would address that concern while enabling compliance with FATCA. No details have been provided regarding this new approach; however, we have heard that the model agreement may be released within the next few weeks.