FATCA Model 2 Agreement Released

The US Treasury has now released the long-anticipated “Model 2” intergovernmental agreement (“IGA”) to facilitate the implementation of FATCA, which is expected to be the template for US agreements with Switzerland, Japan, and certain other countries where there might be domestic legal or administrative impediments to entering into a Model 1 IGA. This paper looks at some of the more significant ways in which Model 2 departs from Model 1.