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FATCA: extension of time for IGAs agreed in substance

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The IRS has issued guidance confirming that jurisdictions that have an IGA agreed in substance prior to 1 July 2014 will continue to be treated as if they have the IGA in effect beyond the original 31 December 2014 deadline. This is dependent on the jurisdiction showing a firm resolve to sign the IGA as soon as possible.

For those jurisdictions that reached an agreement in substance between 1 July and 30 November 2014, the IRS has confirmed that as of 30 November 2014 they will also be treated as if their IGA is in effect. The US Treasury has stated that it will update its list of jurisdictions treated as if they had an IGA in effect accordingly and will carry out a monthly review of this list to assess whether any jurisdictions should be removed.

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