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U.S. Publishes FATCA IGA and MoU with Argentina

15 December 2022

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Treaty Development

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United States-Argentina

The U.S. Department of the Treasury has published the Model 1 FATCA Intergovernmental Agreement (FATCA IGA) signed with Argentina on 5 December 2022. A Memorandum of Understanding (MoU) signed along with the FATCA IGA has also been published. The MoU concerns Argentine financial institutions that have a foreign financial institution (FFI) agreement to be treated as complying with the requirements of section 1471(b) of the U.S. Internal Revenue Code. Section 1471(b) sets out reporting requirements which if not met, result in 30% withholding tax on any withholdable payment to a foreign financial institution. The MoU sets out transitional rules for...