id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
iiclr-18282	Deneault, Sean	Foreign Account Tax Compliance Act: A Step in the Wrong Direction	2014	37	.pdf	application/pdf	16224	913	57	2014] FOREIGN ACCOUNT TAX COMPLIANCE ACT 743 2010 Hiring Incentives to Restore Employment Act (HIRE)125 and the solution proposed by Congress126 and the Obama administration127 to combat the problem of offshore tax evasion.128 FATCA adds sections 1471 through 1475 to the Internal Revenue Code,129 and has led to the promulgation of several Treasury Regulations designed to explain and help implement those provisions.130 The goal of FATCA is to improve tax compliance involving foreign financial assets and offshore accounts to thereby increase tax revenue.131 FATCA achieves this goal by forcing132 three categories of foreign businesses133 to enter into disclosure agreements with the IRS:134 “foreign financial institutions,”135 foreign companies with a “substantial US owner,”136 and “passthru” companies.137 These businesses are forced into disclosure agreements by an ultimatum: comply with the onerous138 and expensive regulations139 or have 30 percent of their US source income withheld.140 All FATCA can do in regard to these individuals is push them further away from large reputable banks located in friendly countries to those that are less desirable.311 The FATCA “stick” is not the right tool for achieving the goal of increased revenue and compliance with US tax laws with respect to the ardent tax avoiders left with assets overseas.	cache/iiclr-18282.pdf	txt/iiclr-18282.txt