**Good luck** with getting Treasury to go for a new hybrid IGA. I think you will find out how unilateral these agreements are. They have already "complexed" FATCA up enough, as it is, so really don't seem them being that receptive. If they open that door for you, then they have to open it for every country in world, and they like the unilateral nature of doing business, not real bi-lateral negotionas.
**If it were me**, I would have a strategy of really throwing the reciprocity aspect back in their face, as they know they can not offer it to you, Even if you don't need any or all of the complex data requirements that they are demanding from you in Article (2) (a) that they say the FFIs in the Bahamas have to supply, insist that what is good for the goose is good for the gander. And you want exactly the same back. That will give lie to how bi-lateral this process is.
**They know they do not have the authority,** and if Congress is forced to face up to the fatca fact, that the costs are blowing back on the homeland shores and the domestic banking industry, this might serve you well. There are those in Congress who hate even the most minor of non resident interest reporting as required by IRS Bulletin 2012-20 http://1.usa.gov/11sGZsl In the last session of Congress, the Posey legislation in the House was pretty bi-partisan against it. http://1.usa.gov/UMyJBN
**One question for you,** Do you have a reference that indicates this statement is true?
> FATCA, which was brought into law in March 2010, is a set of rules set out by the US Internal Revenue Service (IRS) designed specifically to limit tax evasion by US persons living abroad.
**I have never seen** any official statement that expresses this meme although I do see repeated a lot without attribution, but don't think it was actually the case. FATCA sprang out of the JCT frustration with UBS homeland tax evasion schemes. There is nothing in their official press release when they made this proposal that indicates, Americans living abroad were the target. That would be the time to lay out the goals, and it is NOT there.
**I think if you investigate further**, you will find that Americans abroad were not given a moment of consideration when the geniuses in Congress dreamed up FATCA. They are just the after thought, or unintended consequence arising from the unique nature of Citizenship Taxation. They are not the cause of the design, they are the collateral damage.
If you have something that indicates differently, I would be interested in seeing it.
JustMe says...
Niel,
Interesting article.
**Good luck** with getting Treasury to go for a new hybrid IGA. I think you will find out how unilateral these agreements are. They have already "complexed" FATCA up enough, as it is, so really don't seem them being that receptive. If they open that door for you, then they have to open it for every country in world, and they like the unilateral nature of doing business, not real bi-lateral negotionas.
**If it were me**, I would have a strategy of really throwing the reciprocity aspect back in their face, as they know they can not offer it to you, Even if you don't need any or all of the complex data requirements that they are demanding from you in Article (2) (a) that they say the FFIs in the Bahamas have to supply, insist that what is good for the goose is good for the gander. And you want exactly the same back. That will give lie to how bi-lateral this process is.
**They know they do not have the authority,** and if Congress is forced to face up to the fatca fact, that the costs are blowing back on the homeland shores and the domestic banking industry, this might serve you well. There are those in Congress who hate even the most minor of non resident interest reporting as required by IRS Bulletin 2012-20 http://1.usa.gov/11sGZsl In the last session of Congress, the Posey legislation in the House was pretty bi-partisan against it. http://1.usa.gov/UMyJBN
**One question for you,** Do you have a reference that indicates this statement is true?
> FATCA, which was brought into law in March 2010, is a set of rules set out by the US Internal Revenue Service (IRS) designed specifically to limit tax evasion by US persons living abroad.
**I have never seen** any official statement that expresses this meme although I do see repeated a lot without attribution, but don't think it was actually the case. FATCA sprang out of the JCT frustration with UBS homeland tax evasion schemes. There is nothing in their official press release when they made this proposal that indicates, Americans living abroad were the target. That would be the time to lay out the goals, and it is NOT there.
http://bit.ly/V6Aee7
**I think if you investigate further**, you will find that Americans abroad were not given a moment of consideration when the geniuses in Congress dreamed up FATCA. They are just the after thought, or unintended consequence arising from the unique nature of Citizenship Taxation. They are not the cause of the design, they are the collateral damage.
If you have something that indicates differently, I would be interested in seeing it.
Thanks
On QC urges 'hybrid' IGA for Bahamas FATCA compliance
Posted 19 February 2013, 9:15 p.m. Suggest removal