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Release of second model Intergovernmental Agreement - 26/11/2012


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Release of second model Intergovernmental Agreement

On November 14, 2012, the Treasury released a second Model Intergovernmental Agreement (“IGA”) for Cooperation to Facilitate the Implementation of FATCA. As expected, the Model II IGA will require Foreign Financial Institutions (“FFIs”) to enter into agreements with, and report directly to, the IRS

We will keep you updated on any developments in this respect.

Denmark Intergovernmental Agreement

On November 15, 2012, Denmark and the United States signed an Intergovernmental Agreement (“IGA”) to improve international tax compliance and implement FATCA. The agreement is the same Model I agreement (reciprocal version) released in July by the United States and five European Union countries (France, Germany, Spain, Italy and the United Kingdom).

The category of Deemed-Compliant entities under Annex II includes, among others, collective investment vehicles, regulated by Danish law, held by or through Participating FFI(s). This category is similar to the one known as Qualified Collective Investment Vehicles in the Draft Regulations.

If you have any queries regarding the above, please do not hesitate to contact us.

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