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Abstract: 

The Foreign Account Tax Compliance Act (FATCA) is poised to dramatically alter the landscape for U.S. taxpayers maintaining offshore bank accounts. Bank secrecy jurisdictions will no longer be able to provide the protection and anonymity they previously offered, as FATCA will require foreign financial institutions to annually disclose the names of their U.S. accountholders to the Internal Revenue Service or face a 30 percent withholding tax. The now-issued final regulations impose significant compliance obligations, and foreign banks and withholding agents should begin immediate preparations for the new information reporting regime required by FATCA. Taxpayers with undisclosed offshore bank accounts should also prepare for the implementation of FATCA by taking immediate steps to rectify their non-compliance.

Keywords: offshore accounts; FATCA; FFI; NFFE; withholding tax; FBAR; bank secrecy; Global Intermediary Identification Number

Affiliations:  1: Blank Rome LLP; 2: Blank Rome LLP.