Provide for reciprocal reporting ofThe blanks indicate that the measure is deemed to have no impact, positive or negative, on the deficit.
information in connection with the
implementation of FATCA ................... ......... ......... ......... ......... ......... ......... ......... ......... ......... ......... ......... ......... .
This explanation in the Analytical Perspectives:
Provide for reciprocal reporting of information in connection with the implementation of the Foreign Account Tax Compliance Act (FATCA).—In many cases, foreign law would prevent foreign financial institutions from complying with the FATCA provisions of the Hiring Incentives to Restore Employment Act of 2010 by reporting to the IRS information about U.S. accounts. Such legal impediments can be addressed through intergovernmental agreements under which the foreign government agrees to provide the information required by FATCA to the IRS. Requiring U.S. financial institutions to report similar information to the IRS with respect to nonresident accounts would facilitate such intergovernmental cooperation by enabling the IRS to reciprocate in appropriate circumstances by exchanging similar information with cooperative foreign governments to support their efforts to address tax evasion by their residents. The proposal would provide the Secretary of the Treasury with authority to prescribe regulations that would require reporting of information with respect to nonresident alien individuals, entities that are not U.S. persons, and certain U.S. entities held in substantial part by non-U.S. owners, including information regarding account balances and payments made with respect to accounts held by such persons and entities.
But nothing further from the Treasury in its own explanation of the budget.
So we will just have to wait and see, some more. Note that even this brief move forward highlights the aspiration involved in referring to any currently configured IGA as "reciprocal."
After thinking about this for a long time I see almost no chance the US Congress will ever pass this type of legislation. I will put bigger and betters odds on the US getting rid of citizenship based taxation before providing FATCA reciprocity.
ReplyDeleteWhat perhaps will become more interesting is if the EU attempts to apply to the STD unilaterally to the US subsidiaries of EU banks possibility in violation of US state and federal law what the US response will. There already some conservative tea party members of Congress encouraging US banks to "evade" the EU financial transaction tax to "stick it" to the wine drinking European socialists.