While in Model 1 legal systems, FFIs are generally not required to close the accounts of “recalcitrant” account holders, this Model 2 advantage does not depend solely on the fact that the FFI enters into an agreement with the IRS and meets the requirements set out in it (including the aggregate reporting of non-consensual account holders) , but also because the FATCA partner government provides an appropriate exchange of information within six months of the date of an IRS request. If the latter condition is not met, the relevant FFI is required to treat and close account holders related to the object as recalcitrant account holders. Appendix II appears to ignore certain categories of tax-exempt businesses or businesses that are considered compliant and are listed in The Model 1 Schedule. The significance of this omission is not yet clear. In addition, the timing and mechanism for resolving specific issues dealt with under the Model 1 mutual unification procedures remain vague in Model 2. Although Model 2, for example, implies the obligation to cooperate in developing an administrative approach to Passthru payments, unlike Model 1, there is no obligation to participate in such a consultation at any given time. In accordance with the Taiwan Relations Act, the parties to the agreement are the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the United States. The international law firm Withers Worldwide declares the intergovernmental agreement “Model 2” on FATCA facilities published yesterday by the U.S. Treasury. Implementation of FATCA may face legal hurdles. In foreign legal systems, it may be illegal for financial institutions to disclose the necessary account information.  There is controversy over the relevance of intergovernmental agreements (IGAs) to solving one of these intellectually-led problems of Allison`s Christians.   FATCA is used to locate U.S.
citizens (whether or not they live in the United States) and “persons for tax purposes” and to collect and store information, including the total value of assets and social security number. The law is used to recognize assets rather than income. There is no provision in the act that imposes a tax. By law, financial institutions would report information they collect to the U.S. Internal Revenue Service (IRS). As implemented in intergovernmental agreements (IGA) (discussed below) with many countries, each financial institution will first send the U.S. person`s data to the local government. According to the Ukrainian IGA, for example, U.S. person data is sent to the United States.