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FATCA - Intergovernmental Agreements, What Are They and How Do They Work



Friday, October 12, 2012
Product Code - TMW29
Speaker(s): Alan Winston Granwell, DLA Piper and Carol Tello, Sutherland, Asbill & Brennan LLP
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 The Foreign Act Tax Compliance ACT (FATCA) was enacted to curb tax evasions by US persons. It is US centric legislation whose purpose is to obtain information about foreign investments by US persons and not to collect the FATCA withholding tax. However, because of its unilateral nature, its provisions are likely to conflict with local laws, such as privacy and data protection.

Intergovernmental agreements (IGAs) are bilateral agreements between the United States and a foreign jurisdiction that are an alternative means to implement FATCA, avoid local law conflicts and further the objectives of international tax transparency and exchange of information. The United States has proposed two models of IGAs, one of which has two versions.

The webinar will discuss:

  • What is an IGA
  • Why did the US Government propose IGAs
  • How does an IGA implement FATCA
  • What are the differences between the different models and versions of IGAs.
  • What are the differences between IGAs and the FATCA proposed regulations.
  • Which countries are eligible to enter into an IGA.
  • What are the benefits of a country entering into an IGA
  • What is the timing of IGAs
  • What are the broader ramifications of IGAs in the context of tax transparency and exchange of information

Our panelists will be governmental representatives (if available), and US and foreign practitioners who are familiar with FATCA and the foreign aspects and implications of FATCA.

Alan Winston Granwell, DLA Piper and Carol Tello, Sutherland, Asbill & Brennan LLP

 Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international insurance, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring.

Carol Tello is a partner in Sutherland Asbill & Brennan LLP’s Washington office and a member of its Tax Practice Group where she focuses primarily on international tax matters. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters for both business entities and individuals. Much of her work has been for insurance companies in the cross-border context. She has particular experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters, and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions.

Her prior experience includes service in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). While at the IRS, she participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several Tax Court cases, and worked on various regulations and other guidance, including significant participation in developing regulations concerning the taxation of software transactions.

Carol is the author of the BNA TMP 915-3 Payments Directed Outside the United States - Withholding and Reporting Provisions Under Chapters 3 and 4, as well as numerous articles on various tax issues. She also has been recognized in Euromoney’s The Guide to World’s Leading Tax Advisers (2011).