US FATCA Registration Deadline Approaching: 31 December 2014

The British Virgin Islands (the "BVI") has now enacted legislation which allows for the implementation of its commitments under the Model 1B (i.e. non-reciprocal) intergovernmental agreements with the United States, signed on 30 June 2014, (the "US IGA") and with the United Kingdom, signed on 28 November 2013, (the "UK IGA" and, together with the US IGA, the "IGAs").  The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act ("FATCA") in the BVI and the UK IGA provides for reports of tax information to be made to HM Treasury in a similar manner.  The finalisation of the guidance notes is expected imminently, as is the detail regarding how tax information is to be passed to the BVI's International Tax Authority (the "ITA").