United Kingdom And United States Conclude FATCA Intergovernmental Agreement

On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account Tax Compliance Act ("FATCA").¹  The Agreement is based on the model "reciprocal" intergovernmental agreement published on July 26, 2012. A U.S. Treasury Department press release of September 14, 2012 states that the U.S. is in communication with several other governments and expects to sign additional bilateral agreements in the near future, as well as reiterating that the U.S. tax authorities are continuing work on finalizing the proposed U.S. Treasury regulations promulgated under FATCA.²