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More countries may be inclined to seek out tax pacts with the United States following the unveiling of model agreements for government-to-government information exchange under the Foreign Account Tax Compliance Act, practitioners tell BNA. The model accords permit foreign financial institutions to send information on U.S.-owned accounts to their own governments, which then would share the information with IRS, in lieu of the direct reporting otherwise required under the law. Foreign banks that do not tell IRS about accounts belonging to U.S. persons and entities could face a 30 percent withholding tax under FATCA. Treasury is trying to encourage as many tax information exchange agreements as they can, says Linda Carlisle, a partner in the Washington office of White & Case.
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