From Sept 13 Reuters article:
In February, in the face of industry complaints, the U.S. Treasury Department said some countries could comply by collecting required financial data from their home-country institutions and forwarding it to the United States.
Initially, Treasury said that France, Germany, Italy, Spain and the United Kingdom would be allowed to take this “intergovernmental approach.” Japan and Switzerland were later added to that list under a different model.
The UK on Friday became the first country to finalize a tax information-sharing pact with the United States under FATCA.
The U.S.-UK agreement, pending approval by Parliament, spares UK banks, funds and other financial companies from reporting client information directly to the United States.
Treasury is now negotiating with at least 40 countries for FATCA tax information-sharing pacts, tax lawyers said.
A Treasury FATCA negotiating team is scheduled to meet with foreign financial businesses on Thursday in Paris and on September 26 in Singapore on tax information exchanges.
Bilateral agreements to implement FATCA are “a workaround,” said Mark Matthews, a lawyer at Caplin & Drysdale and former head of the criminal investigation division at the Internal Revenue Service.
Note: Caplin & Drysdale, mentioned above, is home to Scott D. Michel and H. David Rosenbloom, who have written important articles on FATCA. Michel has also testified before the Canadian House of Commons Finance Committee on tax related issues.