英文摘要 |
With the aim to fight against offshore tax avoidance and evasion by American citizens and residents through Foreign Financial Institutions (FFIs) reporting system, the US Congress enacted Foreign Account Tax Compliance Act (FATCA) in 2010. To resolve the conflict between FACTA and the domestic laws of FFIs, the US Treasury has issued Intergovernmental Agreements(IGA) models in succession, as model inter-governmental agreements for the implementation of FATCA between US and FATCA partner jurisdictions. In this article, through detailed comparison and analysis of IGA models, three core issues would be discussed. Firstly, what's the relationship between FATCA and IGA. Secondly, whether an international automatic exchange of information mechanism has been established by IGA. Lastly, what are the differences among different IGA models and what sort of tax jurisdiction they are suitable for respectively? |