Zoe Andrews and J. Leonard Teti II revisit the FATCA IGA entered into by the UK in September and suggest it is time for a new approach to FATCA in the European loan market
On 12 September the UK and the US signed the first intergovernmental agreement (IGA) relating to the implementation of FATCA which follows very closely the provisions in the ‘Model I’ IGA published in July by the US and five major European jurisdictions. There was more good news on 24 October when the IRS issued Announcement 2012–42 (available via www.lexisurl.com/BmMdB) which pushes back FATCA withholding on gross proceeds from 2015 to 2017 and provides a generous grandfathering rule for obligations that...
