In February 2012, the Internal Revenue Service issued proposed regulations regarding the implementation of the Foreign Account Tax Compliance Act (FATCA), a statute that was included in the Hiring Incentives to Restore Employment (HIRE) Act of 2010 as a revenue raiser.1 Congress drafted FATCA as a reaction to the disclosure in recent years of unreported accounts held by U.S. taxpayers at Swiss and other overseas financial institutions. These accounts were either reported by ...

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