This should allow the IRS to take the position that any relevant FATCA partner jurisdiction is FATCA compliant and eliminate the need to subject these FFIs to FATCA withholding. FATCA partner jurisdictions approved the model agreement and called for the early conclusion of bilateral agreements on the basis of the model; However, each FATCA partner jurisdiction should also adopt local legislation to fully implement this intergovernmental approach, and so there is some uncertainty as to exactly how this approach will be implemented and its impact on habitats. Payments made under a facility agreement should not be subject to FATCA withholding unless the United Kingdom, France, Germany, Italy and Spain have approached the US authorities and two types of model intergovernmental agreement (“IGA”) are concluded to address some of these issues. . . .