On 8 October 2015, New Zealand signed two competent authority arrangements (“CAAs”) with the U.S. in accordance with the previously signed IGA (Link). Α CAA is a bilateral agreement between the U.S. and a treaty partner to clarify or interpret treaty provisions. These CAAs establish the procedures for the automatic exchange obligations and for the exchange of information between the U.S. and New Zealand (Link). The second CAA concerns the meaning of the term “resident in New Zealand” when applied to a Financial Institution that is a trust (except for a “unit trust” that is deemed to be a company for purposes of the Income Tax Act 2007) (Link).
On 7 October 2015, Romanian President Klaus Iohannis approved a law ratifying the IGA (Link) which was signed with the United States in May.
On 12 October 2015, the Israel Tax Authority (ITA) announced that it would extend its voluntary tax disclosure program until 30 June 2016, which was originally slated to expire on 6 September 2015. This extension will apply for both the anonymous and fast-track programs. More information can be found on the ITA’s website (Link).
In late September and early October 2015, the U.S. signed Competent Authority Arrangements (“CAAs”) with the Czech Republic (Link), Hungary (Link) , India (Link), Liechtenstein (Link) and Mauritius (Link) in accordance with the IGAs previously signed with these jurisdictions. In general, a Competent Authority Agreement is a bilateral agreement between the U.S. and a treaty partner to clarify or interpret treaty provisions (Link). These CAAs establish the procedures for the automatic exchange obligations and for the exchange of information between these jurisdictions.
Link to US Tax Insights: US publishes first FATCA competent authority arrangements
On 2 October 2015, the Internal Revenue Service announced the exchange of financial account information with some foreign tax administrations according to the Foreign Account Tax Compliance Act (“FATCA”) (Link).
On 29 September 2015, the IRS released Draft Form 8809-I (Link) with instructions (Link). Form 8809-I is used to request an initial or additional extension of time to file Form 8966 “FATCA Report” (Link) for the current tax year and should be filed before the due date of Form 8966.
The draft instructions state: File Form 8809-I as soon as you know an extension of time to file is necessary, but not before January 1 of the filing year. Form 8809-I must be filed by the due date of Form 8966. The due date for filing Form 8966 is March 31 of the year following the year to which the Form 8966 relates, unless you are an FFI reporting under a Model 2 IGA (reporting Model 2 FFI) with a different reporting date specified in the applicable Model 2 IGA. If you are requesting an additional hardship extension, Form 8809-I must be filed by the first extended due date of Form 8966.
On 8 September 2015, Montserrat signed an IGA with the United States of America to improve international tax compliance and to implement FATCA (Link).
On 14 September 2015, Cambodia signed an IGA with the United States of America to improve international tax compliance and to implement FATCA (Link).
On 18 September 2015, the Inland Revenue Authority of Singapore (IRAS) issued updates regarding the transmission of FATCA reports to the IRAS, via the International Data Exchange Services (IDES) within Section 4 of its FATCA page (Link). More precisely, Reporting Singapore FIs will transmit their FATCA reports to IRAS via the IDES Gateway and will be able to upload and transmit a file using web UI or SFTP. Reporting Singapore FIs will also receive alerts from IDES regarding the submission of FATCA reports. This is in addition to the General FAQs (Link) FATCA Filing FAQs (Link), both of which were last updated on 2 September.
On 18 September 2015, Australia issued a draft CRS law (Link) and launched a consultation period through 9 October 2015 (Link).