In April 2014, the U.S. Treasury and the IRS announced that all legal systems that enter into “essential agreements” and agree to the publication of their compliance status by July 1, 2014 were treated in such a way that they had an IGA until the end of 2014, ensuring that no sanctions were imposed during that period, while more jurisdictions had the opportunity to conclude formal IGas.   Two citizens of two U.S.-Canadian states, Virginia Hillis and Gwendolyn Louise Deegan, who live in Canada, sued the Canadian government (particularly the Attorney General of Canada and the Minister of National Revenue) before the Federal Court of Canada in 2014, claiming (among other things) that the intergovernmental agreement between the United States and Canada, which implements fatca, was contrary to the Canadian Charter of Rights and Freedoms , particularly against the provisions on discrimination on the basis of nationality.     The complaint was prepared by a group called Alliance for the Defence of Canadian Sovereignty (ADCS).  In 2015, the Federal Court of Canada dismissed the complaint and upheld the intergovernmental agreement.   The Bundesgerichtshof also dismissed the appeals in 2019 although another appeal may follow before the Federal Court of Appeal.  Sometimes these documents are merged into a large document (often called an investment agreement), but for clarity reasons, they are usually separated. Previously, there were few reliable estimates of the additional cost to the U.S. financial service, although it seems certain that most of the costs seem to be borne by the financial institutions involved and, to a lesser extent, by foreign tax authorities that have signed intergovernmental agreements.   The FATCA bill approved an additional 800 IRS employees (estimated cost of $40-$160 million per year). According to an TIGTA report, the cost of developing the XML FATCA data site is $16.6 million ($2.2 million above the budgeted amount). “However, the IRS also submitted a budget request of $37.1 million for funding for the implementation of FATCA for 2013, including costs for auditors and enforcement officers for FATCA, as well as IT development costs.