The Foreign Account Tax Compliance ActThe Foreign Account Tax Compliance Act

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 several overseas banks as part of a settlement with U.S. judicial and regulatory authorities or self-disclosed by U.S. individuals who participated in the various voluntary disclosure (amnesty) programs that the IRS has set up in recent years. 

FATCA introduces a repo...