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.   The IGA is simply an acronym for an intergovernmental agreement. To implement FATCA, the U.S. government has developed two forms of AIG: the Model 1 and Model 2 agreements. As part of a Model 1 agreement, foreign financial institutions report information about U.S.-related accounts to their national tax administration. The national tax authority then forwards this information to the U.S. government. Many Model 1 IGAs also include An Appendix II that lists country-specific financial institutions that are issued as compliant. In some countries, AIG Model 2 has addressed concerns that the FATCA regime may violate local or national laws. Under a Type 2 agreement, the financial body can provide information directly to the IRS.
The U.S. Treasury Department (“Treasury”) and the IRS regularly publish updates that announce jurisdictions with an IGA in effect, through a listing on the Treasury and IRS websites. This list also includes legal systems that, for the most part, have agreements with the United States on the terms of the IGA and have agreed to appear on the site, although these agreements have not been signed. The most recent summary list of countries that have signed the IGAs and negotiating countries so far is available on the left in this article. 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. Agreements generally require Parliamentary approval in the countries with which they are concluded, but the United States does not want to ratify these agreements as a treaty. ALERT: Updated Withholding 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, which were originally published in the form of the 2003-64, 2003-2 C.B.