The National Law Review has just posted a new article by three partners and associates of McDermott Will and Emery, based in Boston and Chicago. It details FATCA obligations and repercussions for multinational employers, focussing on non-U.S. retirement plans:
What You Need to Know About Foreign Account Tax Compliance Act’s (FATCA) Impact on Non-U.S. Retirement Plans
Beside the usual canard that “An intergovernmental approach to FATCA solves these compliance issues, significantly reduces FFI costs and simplifies tax administration”, there was this statement on the status of IGA’s worldwide:
“As of March 15, 2013, Denmark, Germany, Ireland, Italy, Mexico, Norway, Spain, Switzerland and the United Kingdom have initialed or signed IGAs with the United States. It is likely that other countries will adopt IGAs, as the Treasury is engaged with more than 50 countries and jurisdictions to implement the reporting and withholding provisions of FATCA. It is anticipated that IGAs will be entered into with the following countries in the coming months: Canada, Finland, France, Guernsey, Isle of Man, Japan, Jersey and the Netherlands.”
I cannot speculate on the authors’ information sources, but here’s just one more sign pointing towards a Canadian IGA in the not-too-distant future. As Arrow has previously suggested, we Canadians may very well be thrown under the next omnibus bill the feds roll-out.