Discover and read the best of Twitter Threads about #FATCAIGA
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@AmerIronCurtain asks: 1. What would it take for Belgium to get out of the #FATCA IGA? 2. What would it take to get out of the #savingclause? 3. Does the Belgium decision mean that the #FATCAIGA is illegal? Interesting questions ...
1. Article 10 of #FATCA IGA contains a notice provision that allows each country to withdraw from the agreement. But, withdrawing from the agreement leaves Belgium "subject" (pun intended) to the direct application of FATCA rules in the IRC (1471 - 1474) home.treasury.gov/system/files/1… 
2. Par 4 of Article 1 of US/Belgium treaty contains #savingclause. Belgium agrees US can tax US citizens (with exceptions) regardless of treaty. Change requires treaty amendment. But US could suspend and allow US citizens to be treated as nonresidents. irs.gov/pub/irs-trty/b…
