On December 18, HM Treasury and HMRC released the draft International Tax Compliance (United States of America) Regulations 2013 (“UK Draft Regulations”) to implement the UK-US IGA and simultaneously released draft guidance notes and a summary of responses to the consultation which sought views on how the Government intends to legislate to deliver the commitments made in the UK-US IGA.
The UK Draft Regulations give more clarity in respect of the legislation "Draft Clauses & Explanatory Notes for the Finance Bill 2013" published on the 11th December and what financial institutions within the UK will need to do to identify and report ‘specified US persons’ from 1st January 2014. However, a number of areas of significant uncertainty remain and that will continue to be the case at least until the final US FATCA regulations and details of any registration process a financial institution is required to undertake are available.
