December was a fruitful month for the US Treasury Department’s efforts to implement FATCA. The Treasury Department inked another six FATCA bilateral agreements which increases the total number of bilateral agreements to 18.

The Malta, Netherlands, Guernsey, Isle of Man, Jersey agreements are based on the Model 1A treaty and requires the foreign financial institutions from those countries to report US account holders to their domestic government, which in turn will report those accounts to the US. Similarly, US financial institutions are required to report their foreign account holders to the US and the US will report those accounts to each foreign government. The Bermuda agreement is based on the Model 2 treaty and requires that each Bermuda financial institution report their US account holders directly to the United States

FATCA implementation is moving along and it appears that foreign countries are getting more comfortable with the idea. The first hard deadline for FATCA implementation is July 1, 2014, when withholding agents are supposed to begin withholding. Expect to see many more bilateral agreements signed in the next couple months.