Six takeaways from proposed FATCA rules issued by the U.S. Treasury Department & IRS



Revised models of FATCA IGAs

Closing the distance

On 4 November 2013 the US Treasury released revised versions of the Model 1A, Model 1B and Model 2 Intergovernmental Agreements (IGAs).

Deloitte has summarised the recent changes for your convenience.

Key changes

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Revised FATCA IGA Models

For revised Model 1A and Model 1B IGAs, the key changes include:

  • Extension of the definition of a Financial Account
  • Revised definition of a Specified US person to exclude certain tax-exempt trusts
  • Clarification that a FATCA Partner FI can continue to be in compliance even though it has related entities and branches that are Nonparticipating FIs due to the expiration of the 2 year transitional period for Limited FFIs and branches.
  • Compulsory notification when a Competent Authority has detected administrative or other minor errors


For revised Model 2 IGAs, the key changes include:

  • A similar revised definition of a Specified US person and a similar clarification in relation to group entities that are Nonparticipating
  • An express requirement that the Reporting FIs must register with the IRS via the IRS FATCA registration website in order to be treated as compliant 
  • Updated verification and enforcement provisions

The revised Model Agreements can be found on the US Treasury website

How can we help?

Deloitte has a FATCA global centre of excellence aimed specifically at helping our clients analyse their responsibilities and risks to develop a tailored FATCA implementation plan. 

Our professionals have a deep understanding of the tax, operational, technology and regulatory implications of FATCA. We can:

  • Advise on your FATCA obligations
  • Identify and categorise all entities within scope
  • Develop a compliance framework to meet your requirements
  • Conduct a data mining exercise to identify US persons and classify client base according to a risk-based approach
  • Advise on enhancements to data structure, collection, calculation and reporting processes
  • Develop policies, procedures, workflows, new reporting and monitoring controls
  • Staff training
  • FACTA PMO and programme execution


Deirdre Power

Partner - Tax


Eugene O'Keeffe

Director - Tax

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