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.   ALERT: Updated Holding Foreign Partnership (WP) and Withholding Foreign Trust (WT) Agreements have been published and published on the FATCA website. The two updated agreements are presented in the 2014-47 PDF Income Procedure, which updates and replaces the WP and WT agreements, originally published as the 2003-64 income procedure, 2003-2 C.B 306. Liu Xiangmin, deputy managing director of the People`s Bank of China`s Legal Affairs of the People`s Bank of China, said: “Chinese banking and tax legislation and legislation do not allow Chinese financial institutions to comply directly with FATCA.”  The U.S. Treasury suspended negotiations with Russia in March 2014.  Although Russia does not rule out an agreement, it requires full reciprocity and the abandonment of U.S. extraterritoriality before signing an IGA.   Russian President Vladimir Putin signed a law on 30 June 2014 authorizing Russian banks to transmit FATCA data directly to US tax authorities after first disclosing the information to the Russian government.  Russian banks must first obtain the customer`s consent, but may refuse the service if that consent is not given.
 Bangladeshi banks that have U.S. taxpayer accounts may report to the IRS, but they require prior consent from their customers.  The U.S. Treasury has published model GIs that follow two approaches. In Model 1, the partner country`s financial institutions report information about U.S. accounts to the tax administration of the partner country. This tax authority then makes the information available to the United States. Model 1 is available in a cross-version (Model 1A) where the United States will also share information on the partner country`s taxpayers with the partner country and a non-reciprocal version (Model 1B).
Under Model 2, financial institutions in partner countries go directly to the U.S. Internal Revenue Service and the partner country is committed to reducing all legal barriers to these reports.  Model 2 is available in two versions: 2A without a tax information exchange agreement (TIEA) or Double Tax Convention (DTC), and 2B for countries that already have a TIEA or DTC.