The term "FATCA" has been in circulation for what seems like a very long time. However, recent developments have substantially altered the landscape of FATCA in the United Kingdom. Now that the application of FATCA to UK financial institutions has taken on a discernable shape, this Briefing Paper explains that shape, how it has developed and what further developments might be expected.
The US Hiring Incentives to Restore Employment Act 2010 (known as "HIRE"), introduced the Foreign Account Tax Compliance Act – FATCA. The genesis of FATCA is the desire by the Internal Revenue Service (IRS) to combat tax evasion by US persons through the use of undeclared non-US accounts. As the US personal tax system is based on citizenship, US persons do not need to be resident in the US for US tax to apply to them....
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