and PFIC inclusions constitute income for purposes of the 95% income test. 2012112727 November 2012 Treasury issues Model 2 FATCA Intergovernmental Agreement The release of Model 2 IGA has been anticipated for some time and is an important part of the developing body of guidance on FATCA. 2012111818 November 2012 IRS Chief Counsel Advice address criteria for Forms W-8 The CCA contains language by