Wow, they got a really BIG and I mean BIG country to sign on.

http://www.fsitaxposts.com/wp-content/uploads/2012/11/US-Denmark-IGA-model-1.pdf

Agreement is very similar to that of the UK except:

1. Small Financial Institutions with Local Client Base

A Danish Financial Institution that meets all of the following requirements:

a. The Financial Institution must be licensed and regulated under the laws of Denmark;

b. The Financial Institution must have no fixed place of business out-side Denmark;

c. The Financial Institution must not solicit account holders outside Denmark. For this purpose, a Financial Institution shall not be consid-ered to have solicited account holders outside of Denmark merely be-cause it operates a website, provided that the website does not specifi-cally indicate that the Financial Institution provides accounts or ser-vices to nonresidents or otherwise target or solicit U.S. customers;

d. The Financial Institution must be required under the tax laws of Denmark to perform either information reporting or withholding of tax with respect to accounts held by residents of Denmark;

e. At least 98 percent of the accounts by value provided by the Finan-cial Institution must be held by residents (including residents that are entities) of Denmark or another Member State of the European Union;

f. Subject to subparagraph 1(g), below, beginning on January 1, 2014, the Financial Institution does not maintain accounts for (i) any Speci-fied U.S. Person who is not a resident of Denmark (including a U.S. Person that was a resident of Denmark when the account was opened but subsequently ceases to be a resident of Denmark), (ii) a Nonpartic-ipating Financial Institution, or (iii) any Passive NFFE with Control-ling Persons who are U.S. citizens or residents;

g. On or before January 1, 2014, the Financial Institution must im-plement policies and procedures to monitor whether it provides any account held by a person described in subparagraph 1(f), and if such an account is discovered, the Financial Institution must report such ac-count as though the Financial Institution were a Reporting Danish Fi-nancial Institution or close such account;

h. With respect to each account that is held by an individual who is not a resident of Denmark or by an entity, and that is opened prior to the date that the Financial Institution implements the policies and pro-cedures described in subparagraph 1(g), above, the Financial Institu-tion must review those accounts in accordance with the procedures de-scribed in Annex I applicable to Preexisting Accounts to identify any U.S. Reportable Account or account held by a Nonparticipating Finan-cial Institution, and must close any such accounts that were identified, or report on such accounts as though the Financial Institution were a Reporting Danish Financial Institution;

i. Each Related Entity of the Financial Institution must be incorpo-rated or organized in Denmark and must meet the requirements set forth in this paragraph; and 33

j. The Financial Institution must not have policies or practices that discriminate against opening or maintaining accounts for individuals who are Specified U.S. Persons and who are residents of Denmark.

In one regard this announcement is relatively good news as I have had suspiscions they were intending to make announcement at the end that they signed with 50+ countries. Instead it looks like they are going out with announcements in dribs and drabs. It is still in my opinion weird for Denmark to be signing prior to lets say Germany.