The Treasury Department and the IRS recently released a final package of regulations to implement the Foreign Account Tax Compliance Act and amend the regulations to align them with existing tax rules.

FATCA was included as part of the HIRE Act of 2010, with the goal of combating offshore tax evasion by requiring foreign financial institutions to report on the holdings of U.S. taxpayers, or else face stiff penalties. The law has provoked considerable resistance from foreign banks and governments, as well as U.S. expatriates and dual citizens abroad, with many foreign banks refusing to do business with U.S. citizens.

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