Spain and the United States signed an IGA on 15 May 2013. The Spanish IGA is also similar to the British IGA, since it is a mutual agreement. In addition, Annex I has been updated to include a 90-day abatement period for a signposted Spanish IF to document an already existing account holder who, at the end of a previous calendar year, no longer meets a de minimis documentation threshold. In recent years, efforts to ensure tax compliance of offshore investments have intensified considerably. To this end, U.S. law has advocated the use of data information exchange agreements around the world as part of an initiative called the Foreign Account Tax Compliance Act (FATCA). The Irish IGA was signed with the United States on 21 December 2012. Ireland Finance Act 2013 (published on 13 February 2013 and entered into force on 27 February 2013). The Act empowers the Secretary of the Treasury to transpose into Irish law the rules relating to the registration and reporting requirement of Irish FIs. The draft Irish rules and guidelines of the IGA, published on 31 May 2013, contain provisions concerning foreign subsidiaries or branches of an Irish FI, governed by agreements concluded in the foreign territories where they are established.20 Final rules and guidelines are expected by the end of June 2013.
On 7 June 2013, Switzerland and the United States signed a Memorandum of Understanding ("MoU"). The MoU summarised the commitments of the Swiss FIs within the framework of the IGA. The MoU also gives the Swiss tax authorities some flexibility to apply the definitions of the US rules rather than those of the IGA agreement as long as the purpose of the agreement is not thwarted.26 As part of the implementation of the IGA, a bill (separate legislation from the MoU) by the Federal Council would allow Swiss banks to cooperate with the US authorities in disclosing FATCA27 information. The lower house of the Swiss Parliament rejected the debate on the proposal of 5 June 2013. On June 19, 2013, the House of Commons again rejected debate on the bill, dethough the upper house had previously confirmed support for the bill. The bill is currently scheduled for reintroduction in July 2013. . . .