Final FATCA Regulations: Additional Relief - But Are Intergovernmental Agreements the Way Forward?

On January 17, 2013, the Internal Revenue Service (the IRS) and Treasury Department released final regulations (the Final Regulations) that implement the withholding and information reporting provisions of the Foreign Account Tax Compliance Act (FATCA). While the Final Regulations, which are more than 500 pages long, are in many respects similar to the proposed regulations released on February 8, 2012 (the Proposed Regulations), they contain significant modifications and additions to the Proposed Regulations that attempt to address the many concerns raised by commentators regarding the burdens and legal impediments imposed by FATCA.