As previously reported here:
and here:
http://www.repealfatca.com/index.asp?idmenu=4&title=News&idsubmenu=130
the Obama administration has been trying for some time, without success, to sneak some form of FATCA reciprocity past Congress to avoid any embarassing pants-on-fire confrontations with IGA signatories who were apparently promised the moon by American FATCA negotiators. Seems they’re at it again, with a duplicitous new twist, as the following links reveal:
http://www.jdsupra.com/legalnews/treasurys-fincen-proposes-rules-forcing-79017/
http://www.treasury.gov/press-center/press-releases/Pages/jl2595.aspx
http://www.fincen.gov/statutes_regs/files/CDD-NPRM-Final.pdf
In a nutshell, Treasury aims to glue just enough sequins onto its FinCEN (Financial Crimes Enforcement Network) CDD (Customer Due Diligence) requirements to convince IGA suckers that it is finally forcing domestic financial institutions to reveal the beneficial owners of accounts held by foreigners in the US. Since there is actually plenty of wiggle-room in the reporting thresholds, most such account holders will simply re-structure their ownership profiles and thus avoid reporting to their home countries, but no matter – the whole point of the exercise is merely to create a convincing-enough facsimile of reciprocity that the IRS will finally have the fig leaf it so desperately craves, not only for the FATCA club, but for its G8 G7 partners as well.
Now, in true FATCA IGA style, the proposed new legislation intends to simply bypass pesky Congressional authority altogether by being presented as a mere amendment to existing BSA (Bank Secrecy Act) regulations. Some bright light at Treasury finally made the right connection, thinking, hey, the ruse has worked fine for the IGA’s, so why not for DATCA?
Wonder how long it will take for Bill Posey to catch-on to this new effort?
@Neill: sounds right, Innocente & I both got the same count as well
http://isaacbrocksociety.ca/2014/07/29/the-federal-register-timeliness-date-of-filing-and-date-of-publication/comment-page-2/#comment-2491142
will start a new thread once I look over the list more closely
@George
At least non-USC snowbirds have a choice as to whether they want to be US taxpayers or not. No US citizen in the galaxy has that choice.