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B. G., Opalesque Geneva:

The United States and Switzerland have recently made a transition from a "Model 2" to a "Model 1" intergovernmental agreement (IGA) concerning the Foreign Account Tax Compliance Act (FATCA).

This change will be effective January 1, 2027, allowing time for necessary adjustments in Swiss domestic law and compliance by Swiss financial institutions.

The New IGA is the culmination of years of negotiations between the two countries.

So far, the U.S. has entered into IGAs with 113 foreign jurisdictions, reports law firm Seward & Kissel's Tax Group. FATCA IGAs are bilateral agreements facilitating FATCA implementation in foreign jurisdictions, categorized as either Model 1 or Model 2. While the majority of jurisdictions have Model 1 IGAs, Switzerland and a few others, such as Bermuda, previously signed Model 2 IGAs. (Switzerland's agreement was made in 2014.)

Under Model 2 IGAs, financial institutions directly disclose information on consenting U.S. account holders to the IRS, while data on non-consenting account holders can be requested by the IRS through administrative assistance channels. The U.S. does not reciprocate by sharing data on accounts held by residents of ......................

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