United States and Ireland sign a bilateral FATCA Intergovernmental Agreement

January 2013
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United States and Ireland sign a bilateral FATCA Intergovernmental Agreement

At a glance

Annex II of the US-Ireland IGA identifies the Irish institutions and products that are to be excluded from the FATCA requirements and closely follows the Model I Agreement issued in July 2012 by the governments of France, Germany, Italy, Spain, the UK and the US, but also provides that where a new individual account is excluded from the documentation requirement at the time it is opened because the account balance is de minimis, but subsequently becomes subject to documentation because it exceeds the threshold, a Financial Institution will have ninety (90) days to document the account.

On 21 December 2012, the Chargé d’affaires at the US Embassy in Ireland and the Minister for Finance of Ireland signed an intergovernmental agreement (the US-Ireland IGA) under the provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). As anticipated, Annex II of the US-Ireland IGA specifically identifies the Irish institutions and products that are to be excluded from the FATCA requirements because they are seen as presenting a low risk of being used to evade US tax.

The US-Ireland IGA closely follows the Model I Agreement issued in July 2012 by the governments of France, Germany, Italy, Spain, the UK and the US, but also provides that where a new individual account is excluded from the documentation requirement at the time it is opened because the account balance is de minimis, but subsequently becomes subject to documentation because it exceeds the threshold, a Financial Institution will have ninety (90) days to document the account.