"Notice 2023-11: Temporary Relief for Permanent FATCA Problems" by Robert Goulder

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Tax Notes International, January 16, 2023

'Notice 2023-11: Temporary Relief for Permanent FATCA Problems' by Robert Goulder*
This article highlights many of the inherent problems with FATCA and recommends Same Country Exemption (SCE) as a potential way to help alleviate some of the problems.
'Notice 2023-11 raises a basic question: When a national revenue body is forced to place so many behavioral demands on external parties, is the problem that some people in faraway places are being recalcitrant or that Congress built the U.S. regime on a deviant concept (citizenship-based taxation) that doesn’t mesh with how the rest of the tax world operates? As I’ve written before, FATCA wouldn’t be nearly so offensive if the United States adhered to residence-based taxation — the global norm. Other nations have sophisticated individual income tax systems, so why does no other country find itself imposing similar demands on outsiders?'
*ACA is not quoted in this article, but ACA's work has been included in the article.