At the same time Treasury released the proposed rules, the United States announced in a joint statement its intent to enter into FATCA agreements with five European governments to help combat tax evasion.
France, Germany, Italy, Spain, and the United Kingdom said they would jointly develop a framework to collect and send information about offshore accounts held by Americans from their FFIs to the IRS.
Once the framework is finalised, FFIs in those countries would not have to enter into separate agreements with the IRS, but would still be required to apply for FFI EINs to identify themselves as participating FFIs.
In return, the United States would collect and share information with those five countries about accounts held by their citizens in U.S. financial institutions. However, financial institutions in other countries must still enter into agreements with the IRS on their own.
A number of key financial places such as Luxembourg, Ireland, and Switzerland have not yet revealed their positions as to their potential participation in this bilateral framework.