On 1 January 2017, the US Treasury will start treating some, if not all, nations that have not activated their intergovernmental agreements or IGAs with it in respect of the Foreign Accounts Tax Compliance Act as though they have no IGAs at all.
The Treasury will, on that date, begin updating the IGA list to ensure that certain jurisdictions that have not brought their IGAs into force will no longer be treated as if they have an IGA in effect. Each jurisdiction with an IGA that is not yet in force and that wishes to continue to be treated as having an IGA in effect must, by 31 December, give the Treasury a detailed explanation of why and a step-by-step plan that it intends to follow in order to sign the IGA (if it has not yet been signed) and bring it into force, with expected dates for each step.
In evaluating whether a jurisdiction will continue to be treated as if it has an IGA in effect, the Treasury will consider whether it is "demonstrating firm resolve" to co-operate.
In respect of the timing of the exchange of 'prior year' information upon entry into force of a Model 1 IGA, the Treasury does not intend to find foreign financial institutions to be disobeying the IGA as long as any information for prior years is exchanged before the next 30 September after the obligation to exchange information in accordance with the IGA has taken effect.
The Treasury originally promised a 'grace period' in a 'revised timeline' notice numbered 2013-43.