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ARTICLE · 18 OCTOBER 2018

F.A.T.C.A. – Where Do We Stand Today?

A participating F.F.I. files Form 8966, F.A.T.C.A. Report, annually with the I.R.S. The

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On July 5, 2018, the Treasury Inspector General for Tax Administration ("T.I.G.T.A.") issued a final audit report on enforcement of the Foreign Account Tax Compliance Act ("F.A.T.C.A.") enacted in 2010. It concluded that after spending nearly $380 million, the I.R.S. is still not prepared to enforce F.A.T.C.A. compliance. According to the report, the I.R.S. has taken limited or no action to follow the activities outlined in the F.A.T.C.A. Compliance Roadmap, last updated in 2016.

T.I.G.T.A. found that many Foreign Financial Institutions ("F.F.I.'s") and withholding agents did not include correct Taxpayer Identification Numbers ("T.I.N.'s") for individuals, and as a result, the I.R.S. has not been able to match the data from the forms filed by F.F.I.'s, withholding agents, and taxpayers.

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