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William Byrnes (Texas A&M) tax & compliance articles

Treasury Notifies Countries of More Favorable IGA FATCA Terms

Posted by William Byrnes on November 10, 2014

International Financial Law Prof Blog.

Article 7 of the Model 1 IGA provides that the United States shall notify its partner jurisdictions of any more favorable terms under Article 4 or Annex I of the IGA afforded to another partner jurisdiction.

Based on the BVI IGA, the United States considers the language in italics to be “more favorable
terms” in Annex I, except in those cases where the Agreement already includes such language:

1. Paragraph G of Section VI of Annex I:

G. Alternative Procedures for New Accounts Opened Prior to Entry Into Force of 
this Agreement.

2. Paragraph H of Section VI of Annex I:

H. Alternative Procedures for New Entity Accounts Opened on or after July 1, 2014, and before January 1, 2015.

The notice was sent to the following jurisdictions – see International Financial Law Prof Blog

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