FATCA Announcement On IGAs And Registration Deadlines

The US Treasury and IRS have recently issued Announcement 2014-17 (the "Announcement"), which essentially clarifies two important aspects of the implementation of FATCA.  The Announcement can be viewed here. 

Firstly, jurisdictions listed on the IRS/Treasury websites as having an inter-governmental agreement ("IGA") in effect will also now include jurisdictions that have reached agreement with the US on the substantive terms of an IGA, before 1 July 2014, and have consented to be included on the Treasury and IRS list, even though the IGA has yet to be signed. 

The affected jurisdictions can be viewed here, which includes the British Virgin Islands ("BVI") and Brazil. 

This is of significance to those Financial Institutions domiciled in such listed jurisdictions as they will be permitted to register on the FATCA registration website, and certify their status to a withholding agent, as if they were domiciled in a jurisdiction with a signed IGA.  Reporting