The Foreign Account Tax Compliance Act ("FATCA") was
introduced by the United States in 2010 as part of the US Hiring
Incentives to Restore Employment Act (known as the HIRE Act). The
purpose of FATCA is to reduce tax evasion by US citizens. FATCA
requires foreign institutions to report information on financial
accounts held by their US customers to the Internal Revenue
Services ("IRS"). The US government has entered
intergovernmental agreements ("IGAs") with various
jurisdictions in order to allow financial institutions to overcome
legal burdens that they might face in complying with their
obligations under FATCA.
The UK government decided to follow in the US government's
steps by requiring its Crown Dependencies and Overseas British
Territories to enter into IGAs which are in a similar form to the
US IGA. The British Virgin Islands ("BVI") has, on 6
March 2014, agreed in principle to enter into a Model 1 IGA with
the US government ("US IGA") and it has entered into
