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Tax Notes Federal (2020)
Tax Notes Federal, January 16, 2023

“Group Voices Compliance Concerns Following IRS FATCA Notice,” by Kiarra M. Strocko
"Despite its relaxation of U.S. taxpayer identification number requirements for some foreign financial institutions, the government isn’t backing down on enforcing reporting obligations under the Foreign Account Tax Compliance Act, American Citizens Abroad (ACA) said."

“'The IRS’s push for FATCA compliance is not going to go away,' ACA said in a January 11 statement. Although taxpayers will now be able to “catch up” or avoid penalties for noncompliance, the IRS will not give them a pass if they don’t have a TIN, the statement says. Charles M. Bruce, legal counsel for ACA, told Tax Notes that 'FFIs and foreign jurisdictions even more visibly will be coaxing American citizens abroad to comply.'”
“'FFIs will probably view this notice as a reasonable step forward,' ACA said in its statement. However, it added, 'taxpayers should view it as a warning that this problem is not going away and that, if they are out of compliance, they need to do something sooner rather than later.' Regarding use of this data, ACA said that the same-country exemption — which was proposed but not added as an amendment to the National Defense Authorization Act — may finally be incorporated into FATCA and that the data will help with tax reform and interest in residence-based taxation."