Article 7 of the Model 1 IGA provides that the United States shall notify its partner jurisdictions 

of any more favorable terms under Article 4 or Annex I of the IGA afforded to another partner 

jurisdiction. For informational purposes only, the model notification letter sent pursuant to 

Article 7 of the Model 1 IGA is attached. The attached letter has been sent to the following 

jurisdictions:

• Canada

• Cayman Islands 

• Costa Rica 

• Denmark 

• France 

• Germany 

• Guernsey 

• Honduras

• Ireland 

• Isle of Man 

• Italy 

• Jersey 

• Malta 

• Mauritius 

• Norway

• Spain 

• United Kingdom 

To confirm whether a jurisdiction has declined the application of any of the terms in the attached 

letter, please contact the relevant jurisdiction.
[Date]

[Name]

[Address]

Dear [ ]:

On behalf of the Government of the United States of America, I am writing to provide you with 

notification pursuant to Article 7 of the Agreement between [the Government of the United 

States and the Government of [FATCA Partner] to Improve International Tax Compliance and to 

Implement FATCA] (the “Agreement”), done at [city], on [date], which reads as follows:

Article 7

Consistency in the Application of FATCA to Partner Jurisdictions

1. [FATCA Partner] shall be granted the benefit of any more favorable terms 

under Article 4 or Annex I of the Agreement relating to the application of 

FATCA to [FATCA Partner] Financial Institutions afforded to another Partner 

Jurisdiction under a signed bilateral agreement pursuant to which the other 

Partner Jurisdiction commits to undertake the same obligations as [FATCA 

Partner] described in Articles 2 and 3 of the Agreement, and subject to the 

same terms and conditions as described therein and in Articles [5 through 9]

of the Agreement. 

2. The United States shall notify [FATCA Partner] of any such more favorable 

terms, and such more favorable terms shall apply automatically under this

Agreement as if such terms were specified in this Agreement and effective as 

of the date of [entry into force][signing] of the agreement incorporating the 

more favorable terms, unless [FATCA Partner] declines [in writing] the 

application thereof. 

The provisions of the Agreement between the Department of the Treasury of the United 

States of America and the Ministry of Finance and Public Credit of the United Mexican States to 

Improve International Tax Compliance Including with Respect to FATCA, signed at Mexico 

City on April 9, 2014, which entered into force on April 10, 2014 (the “Mexico IGA”), that are 

set forth in the attachment to this letter (the “Attachment”) reflect the most favorable terms under 

Article 4 and Annex I of a bilateral agreement, pursuant to which another Partner Jurisdiction 

commits to undertake the same obligations as [FATCA Partner] described in Articles 2 and 3 of 

the Agreement, and subject to the same terms and conditions as described therein and in Articles 

[5 through 9] of the Agreement, that is in force with another Partner Jurisdiction. 

[IN CASES WHERE THE IGA HAS ENTERED INTO FORCE] I hereby notify you, on 

behalf of the Government of the United States of America that, to the extent the Agreement does 

not contain identical terms to those in the Attachment, pursuant to Article 7 of the Agreement, 

[FATCA Partner] is granted the benefit of such more favorable terms. If [FATCA Partner] 

would like to decline the application of any such terms to the Agreement, [FATCA Partner] 
should do so by notifying me of this in writing. I request that you provide this notification in 

writing within 90 days if you are declining the application of any such more favorable terms to 

the Agreement. 

[IN CASES WHERE THE IGA HAS NOT YET ENTERED INTO FORCE] Although 

the Agreement has not yet entered into force, on behalf of the Government of the United States 

of America, I am notifying you that, to the extent the Agreement with [FATCA Partner] does not 

contain identical terms to those in the Attachment, pursuant to Article 7 of the Agreement, 

[FATCA Partner] shall be granted the benefit of such more favorable terms when the Agreement 

enters into force. If [FATCA Partner] would like to decline the application of any such terms 

when the Agreement enters into force, [FATCA Partner] may do so by notifying me of this in 

writing. If you would like to decline the application of any such more favorable terms to the 

Agreement, I request that you provide this notification in writing within 90 days. 

Sincerely,
ATTACHMENT

Based on the Mexico IGA, the United States considers the language in italics to be “more 

favorable terms” in Article 4 and Annex I, except in those cases where the Agreement already 

includes such language:

1. Paragraph 3 of Article 4:

Specific Treatment of Mexican Retirement Plans. The U.S. Treasury Department shall 

treat as a deemed-compliant FFIs or exempt beneficial owners, as appropriate, for 

purposes of sections 1471 and 1472 of the U.S. Internal Revenue Code, Mexican

retirement plans described in Annex II.

2. Paragraph 5 of Article 4:

Special Rules Regarding Related Entities and Branches That Are Nonparticipating 

Financial Institutions. If a Mexican Financial Institution, that otherwise meets the 

requirements of paragraph 1 of this Article or is described in paragraph 3 or 4 of this 

Article, has a Related Entity or branch that operates in a jurisdiction that prevents such 

Related Entity or branch from fulfilling the requirements of a participating FFI or 

deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code or 

has a Related Entity or branch that is treated as a Nonparticipating Financial Institution 

solely due to the expiration of the transitional rule for limited FFIs and limited branches 

under relevant U.S. Treasury Regulations, such Mexican Financial Institution shall 

continue to be in compliance with the terms of this Agreement and shall continue to be 

treated as a deemed-compliant FFI or exempt beneficial owner, as appropriate, for 

purposes of section 1471 of the U.S. Internal Revenue Code, provided that:

3. Paragraph 6 of Article 4:

Coordination of Timing. Notwithstanding paragraphs 3 and 5 of Article 3 of this 

Agreement:

a) the Ministry of Finance of Mexico shall not be obligated to obtain and exchange 

information with respect to a calendar year that is prior to the calendar year with 

respect to which similar information is required to be reported to the IRS by 

participating FFIs pursuant to relevant U.S. Treasury Regulations;

b) the Ministry of Finance of Mexico shall not be obligated to begin exchanging 

information prior to the date by which participating FFIs are required to report 

similar information to the IRS under relevant U.S. Treasury Regulations;

c) the U.S. Treasury Department shall not be obligated to obtain and exchange 

information with respect to a calendar year that is prior to the first calendar year 

with respect to which the Ministry of Finance of Mexico is required to obtain and 
exchange information; and

d) the U.S. Treasury shall not be obligated to begin exchanging information prior to 

the date by which the Ministry of Finance of Mexico is required to begin 

exchanging information.

4. Paragraph 7 of Article 4:

Coordination of Definitions with U.S. Treasury Regulations. Notwithstanding Article 1 

of this Agreement and the definitions provided in the Annexes to this Agreement, in 

implementing this Agreement, Mexico may use, and may permit Mexican Financial 

Institutions to use, a definition in relevant U.S. Treasury Regulations in lieu of a 

corresponding definition in this Agreement, provided that such application would not 

frustrate the purposes of this Agreement.

5. Subparagraph B(3) of Section 1 of Annex I:

Where a balance or value threshold is to be determined as of June 30, 2014 under this 

Annex I, the relevant balance or value shall be determined as of that day or the last day of 

the reporting period ending immediately before June 30, 2014, and where a balance or 

value threshold is to be determined as of the last day of a calendar year under this Annex 

I, the relevant balance or value shall be determined as of the last day of the calendar 

year or other appropriate reporting period. 

6. Paragraph C of Section 1 of Annex I:

As an alternative to the procedures described in each section of this Annex I, Mexico may 

allow Reporting Mexican Financial Institutions to rely on the procedures described in 

relevant U.S. Treasury Regulations to establish whether an account is a U.S. Reportable 

Account or an account held by a Nonparticipating Financial Institution. Mexico may 

allow Reporting Mexican Financial Institutions to make such election separately for each 

section of this Annex I either with respect to all relevant Financial Accounts or, 

separately, with respect to any clearly identified group of such accounts (such as by line 

of business or the location of where the account is maintained). 

7. Paragraph A of Section II of Annex I:

Accounts Not Required to Be Reviewed, Identified, or Reported. Unless the 

Reporting Mexican Financial Institution elects otherwise, either with respect to all 

Preexisting Individual Accounts or, separately, with respect to any clearly identified 

group of such accounts, where the implementing rules in Mexico provide for such an 

election, the following Preexisting Individual Accounts are not required to be reviewed, 

identified, or reported as U.S. Reportable Accounts:

8. Subparagraph A(1) of Section II of Annex I:
Subject to subparagraph E(2) of this section, a Preexisting Individual Account with a 

balance or value that does not exceed fifty thousand ($50,000) dollars as of June 30, 

2014.

9. Subparagraph A(2) of Section II of Annex I:

Subject to subparagraph E(2) of this section, a Preexisting Individual Account that is a 

Cash Value Insurance Contract and an Annuity Contract with a balance or value of two 

hundred and fifty thousand ($250,000) dollars or less as of June 30, 2014.

10. Paragraph B of Section II of Annex I:

Review Procedures for Preexisting Individual Accounts With a Balance or Value as 

of June 30, 2014, that Exceeds Fifty Thousand ($50,000) Dollars (Two Hundred and 

Fifty Thousand ($250,000) Dollars for a Cash Value Insurance Contract or Annuity 

Contract), But Does Not Exceed One Million ($1,000,000) Dollars (“Lower Value 

Accounts”)

11. Subparagraph B(4)(b)(2) of Section II of Annex I:

Documentary evidence, as defined in paragraph D of section VI of this Annex I, 

establishing the Account Holder’s non-U.S. status.

12. Subparagraph C(1) of Section II of Annex I:

Review of Preexisting Individual Accounts that are Lower Value Accounts for U.S. 

indicia must be completed by June 30, 2016.

13. Paragraph D of Section II of Annex I:

Enhanced Review Procedures for Preexisting Individual Accounts With a Balance 

or Value That Exceeds One Million ($1,000,000) Dollars as of June 30, 2014, or 

December 31 of 2015 or Any Subsequent Year (“High Value Accounts”)

14. Subparagraph E(1) of Section II of Annex I:

If a Preexisting Individual Account is a High Value Account as of June 30, 2014, the 

Reporting Mexican Financial Institution must complete the enhanced review procedures 

described in paragraph D of this section with respect to such account by June 30, 2015. If 

based on this review such account is identified as a U.S. Reportable Account on or before 

December 31, 2014, the Reporting Mexican Financial Institution must report the required 

information about such account with respect to 2014 in the first report on the account and 

on an annual basis thereafter. In the case of an account identified as a U.S. Reportable 

Account after December 31, 2014, and on or before June 30, 2015, the Reporting 

Mexican Financial Institution is not required to report information about such account 

with respect to 2014, but must report information about the account on an annual basis 
thereafter.

15. Subparagraph E(2) of Section II of Annex I:

If a Preexisting Individual Account is not a High Value Account as of June 30, 2014, but 

becomes a High Value Account as of the last day of 2015 or any subsequent calendar 

year, the Reporting Mexican Financial Institution must complete the enhanced review 

procedures described in paragraph D of this section with respect to such account within 

six (6) months after the last day of the calendar year in which the account becomes a 

High Value Account. If based on this review such account is identified as a U.S. 

Reportable Account, the Reporting Mexican Financial Institution must report the required 

information about such account with respect to the year in which it is identified as a U.S. 

Reportable Account and subsequent years on an annual basis, unless the Account Holder 

ceases to be a Specified U.S. Person.

16. Paragraph F of Section II of Annex I:

Preexisting Individual Accounts That Have Been Documented for Certain Other 

Purposes. A Reporting Mexican Financial Institution that has previously obtained 

documentation from an Account Holder to establish the Account Holder’s status as 

neither a U.S. citizen nor a U.S. resident in order to meet its obligations under a QI, 

withholding foreign partnership, or withholding foreign trust agreement with the IRS, or 

to fulfill its obligations under chapter 61 of Title 26 of the United States Code, is not 

required to perform the procedures described in subparagraph B(1) of this section with 

respect to Lower Value Accounts or subparagraphs D(1) through D(3) of this section 

with respect to High Value Accounts.

17. Section III of Annex I:

New Individual Accounts. The following rules and procedures apply for identifying 

U.S. Reportable Accounts among Financial Accounts held by individuals and opened on 

or after July 1, 2014 (“New Individual Accounts”).

18. Paragraph A of Section III of Annex I:

Accounts Not Required to Be Reviewed, Identified or Reported. Unless the 

Reporting Mexican Financial Institution elects otherwise, either with respect to all New 

Individual Accounts or, separately, with respect to any clearly identified group of such 

accounts, where the implementing rules in Mexico provide for such an election, the 

following New Individual Accounts are not required to be reviewed, identified, or 

reported as U.S. Reportable Accounts:

19. Paragraph B of Section III of Annex I:

Other New Individual Accounts. With respect to New Individual Accounts not 

described in paragraph A of this section, upon account opening (or within ninety (90) 
days after the end of the calendar year in which the account ceases to be described in 

paragraph A of this section), the Reporting Mexican Financial Institution must obtain a 

self-certification which may be part of the account opening documentation, that allows 

the Reporting Mexican Financial Institution to determine whether the Account Holder is 

resident in the United States for tax purposes (for this purpose, a U.S. citizen is 

considered to be resident in the United States for tax purposes, even if the Account 

Holder is also a tax resident of another jurisdiction) and confirm the reasonableness of 

such self-certification based on the information obtained by the Reporting Mexican 

Financial Institution in connection with the opening of the account, including any 

documentation collected pursuant to AML/KYC Procedures.

20. Paragraph A of Section IV of Annex I:

Entity Accounts Not Required to Be Reviewed, Identified or Reported. Unless the 

Reporting Mexican Financial Institution elects otherwise, either with respect to all 

Preexisting Entity Accounts or, separately, with respect to any clearly identified group of 

such accounts, where the implementing rules in Mexico provide for such an election, a 

Preexisting Entity Account with an account balance or value that does not exceed two 

hundred and fifty thousand ($250,000) dollars as of June 30, 2014, is not required to be 

reviewed, identified, or reported as a U.S. Reportable Account until the account balance 

or value exceeds one million ($1,000,000) dollars.

21. Paragraph B of Section IV of Annex I:

Entity Accounts Subject to Review. A Preexisting Entity Account that has an account 

balance or value that exceeds two hundred and fifty thousand ($250,000) dollars as of 

June 30, 2014, and a Preexisting Entity Account that does not exceed two hundred and 

fifty thousand ($250,000) dollars as of June 30, 2014, but the account balance or value of 

which exceeds one million ($1,000,000) dollars as of the last day of 2015 or any 

subsequent calendar year, must be reviewed in accordance with the procedures set forth 

in paragraph D of this section. 

22. Subparagraph D(2)(b) of Section IV of Annex I:

If the information indicates that the Account Holder is a Financial Institution, or the 

Reporting Mexican Financial Institution verifies the Account Holder’s Global 

Intermediary Identification Number on the published IRS FFI list, then the account is not 

a U.S. Reportable Account. 

23. Subparagraph D(3)(a) of Section IV of Annex I:

Subject to subparagraph D(3)(b) of this paragraph, a Reporting Mexican Financial 

Institution may determine that the Account Holder is a Mexican Financial Institution or 

other Partner Jurisdiction Financial Institution if the Reporting Mexican Financial 

Institution reasonably determines that the Account Holder has such status on the basis of 

the Account Holder’s Global Intermediary Identification Number on the published IRS 
FFI list or other information that is publicly available or in the possession of the 

Reporting Mexican Financial Institution, as applicable. In such a case, no further review, 

identification, or reporting is required with respect to the account.

24. Subparagraph D(3)(b) of Section IV of Annex I:

If the Account Holder is a Mexican Financial Institution or other Partner Jurisdiction 

Financial Institution treated by the IRS as a Nonparticipating Financial Institution, then 

the account is not a U.S. Reportable Account, but payments to the Account Holder must 

be reported as contemplated in subparagraph 1(b) of Article 4 of the Agreement.

25. Subparagraph E(1) of Section IV of Annex I:

Review of Preexisting Entity Accounts with an account balance or value that exceeds two 

hundred and fifty thousand ($250,000) dollars as of June 30, 2014 must be completed by 

June 30, 2016.

26. Subparagraph E(2) of Section IV of Annex I:

Review of Preexisting Entity Accounts with an account balance or value that does not 

exceed two hundred and fifty thousand ($250,000) dollars as of June 30, 2014, but 

exceeds one million ($1,000,000) dollars as of December 31, 2015 or a subsequent year, 

must be completed within six (6) months after the last day of the calendar year in which 

the account balance or value exceeds one million ($1,000,000) dollars.

27. Section V of Annex I:

The following rules and procedures apply for purposes of identifying U.S. Reportable 

Accounts and accounts held by Nonparticipating Financial Institutions among Financial 

Accounts held by Entities and opened on or after July 1, 2014 (“New Entity Accounts”). 

28. Paragraph A of Section V of Annex I:

Entity Accounts Not Required to Be Reviewed, Identified or Reported. Unless the 

Reporting Mexican Financial Institution elects otherwise, either with respect to all New 

Entity Accounts or, separately, with respect to any clearly identified group of such 

accounts, where the implementing rules in Mexico provide for such election, a credit 

card account or a revolving credit facility treated as a New Entity Account is not 

required to be reviewed, identified, or reported, provided that the Reporting Mexican 

Financial Institution maintaining such account implements policies and procedures to 

prevent an account balance owed to the Account Holder that exceeds fifty thousand 

($50,000) dollars.

29. Subparagraph B(1) of Section V of Annex I:
Subject to subparagraph B(2) of this section, a Reporting Mexican Financial Institution 

may determine that an Account Holder is an Active NFFE, a Mexican Financial 

Institution, or other Partner Jurisdiction Financial Institution if the Reporting Mexican 

Financial Institution reasonably determines that the Account Holder has such status on 

the basis of the Account Holder’s Global Intermediary Identification Number or other

information that is publicly available or in the possession of the Reporting Mexican 

Financial Institution, as applicable. 

30. Subparagraph B(2) of Section V of Annex I:

If the Account Holder is a Mexican Financial Institution or other Partner Jurisdiction 

Financial Institution treated by the IRS as a Nonparticipating Financial Institution, then 

the account is not a U.S. Reportable Account, but payments to the Account Holder must 

be reported as contemplated in subparagraph 1(b) of Article 4 of the Agreement.

31. Subparagraph B(2) of Section VI of Annex I:

NFFE. An “NFFE” means any Non-U.S. Entity that is not an FFI as defined in relevant 

U.S. Treasury Regulations or is an Entity described in subparagraph B(4)(j) of this 

section, and also includes any Non-U.S. Entity that is established in Mexico or another 

Partner Jurisdiction and that is not a Financial Institution.

32. Subparagraph B(2) of Section VI of Annex I:

Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) an Active NFFE, or 

(ii) a withholding foreign partnership or withholding foreign trust pursuant to relevant 

U.S. Treasury Regulations.

33. Subparagraph B(4)(d) of Section VI of Annex I:

The NFFE is a government (other than the U.S. government), a political subdivision of 

such government (which, for the avoidance of doubt, includes a state, province, county, 

or municipality), or a public body performing a function of such government or a 

political subdivision thereof, a government of a U.S. Territory, an international 

organization, a non-U.S. central bank of issue, or an Entity wholly owned by one or more 

of the foregoing; 

34. Subparagraph B(4)(e) of Section VI of Annex I:

Substantially all of the activities of the NFFE consist of holding (in whole or in part) the 

outstanding stock of, and providing financing and services to, one or more subsidiaries 

that engage in trades or businesses other than the business of a Financial Institution, 

except that an Entity shall not qualify for NFFE status if the Entity functions (or holds 

itself out) as an investment fund, such as a private equity fund, venture capital fund, 

leveraged buyout fund, or any investment vehicle whose purpose is to acquire or fund 
companies and then hold interests in those companies as capital assets for investment 

purposes;

35. Subparagraph B(4)(i) of Section VI of Annex I:

The NFFE is an “excepted NFFE” as described in relevant U.S. Treasury Regulations;

36. Subparagraph B(4)(j)(1) of Section VI of Annex I:

It is established and operated in its jurisdiction of residence exclusively for religious, 

charitable, scientific, artistic, cultural, athletic, or educational purposes; or it is 

established and operated in its jurisdiction of residence and it is a professional 

organization, business league, chamber of commerce, labor organization, agricultural or 

horticultural organization, civic league or an organization operated exclusively for the 

promotion of social welfare;

37. Subparagraph B(5) of Section VI of Annex I:

Preexisting Account. A “Preexisting Account” means a Financial Account maintained 

by a Reporting Financial Institution as of June 30, 2014.

38. Subparagraph D(1) of Section VI of Annex I:

A certificate of residence issued by an authorized government body (for example, a 

government or agency thereof, or a municipality) of the jurisdiction in which the payee 

claims to be a resident.

39. Paragraph E of Section VI of Annex I:

Alternative Procedures for Financial Accounts Held by Individual Beneficiaries of a 

Cash Value Insurance Contract. A Reporting Mexican Financial Institution may 

presume that an individual beneficiary (other than the owner) of a Cash Value Insurance 

Contract receiving a death benefit is not a Specified U.S. Person and may treat such 

Financial Account as other than a U.S. Reportable Account unless the Reporting 

Mexican Financial Institution has actual knowledge, or reason to know, that the 

beneficiary is a Specified U.S. Person. A Reporting Mexican Financial Institution has 

reason to know that a beneficiary of a Cash Value Insurance Contract is a Specified U.S. 

Person if the information collected by the Reporting Mexican Financial Institution and 

associated with the beneficiary contains U.S. indicia as described in subparagraph (B)(1) 

of section II of this Annex I. If a Reporting Mexican Financial Institution has actual 

knowledge, or reason to know, that the beneficiary is a Specified U.S. Person, the 

Reporting Mexican Financial Institution must follow the procedures in subparagraph 

B(3) of section II of this Annex I.

40. Paragraph F of Section VI of Annex I:
Reliance on Third Parties. Regardless of whether an election is made under paragraph 

C of section I of this Annex I, Mexico may permit Reporting Mexican Financial 

Institutions to rely on due diligence procedures performed by third parties, to the extent 

provided in relevant U.S. Treasury Regulations.