FOI Decision Letter. Documents Relating To Notice 2024-78 Issued By The United States Internal Revenue Service.

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The ATO released six documents relating to US Internal Revenue Service Notices 2023-11 and 2024-78 concerning Model 1 Intergovernmental Agreement (IGA) jurisdiction obligations under the Foreign Account Tax Compliance Act (FATCA). The request specifically sought communications and memos regarding requirements on page 8 of Notice 2024-78 and page 11 of Notice 2023-11, particularly provisions requiring Model 1 IGA countries like Australia to encourage financial institutions not to discriminate against US citizens providing Tax Identification Numbers. The ATO granted partial access to three documents (with attachments) and refused three documents entirely, citing exemptions under sections 33 and 47E of the FOI Act. Exempt material involved considerations relating to international tax treaties, specifically the US-Australia double taxation convention. No quantified outcomes or compliance figures were disclosed in the decision letter excerpt.